Wednesday, July 31, 2019
China: Civil War and Communist Triumph Essay
* China: Civil War and Communist Triumph CCP gained control of the Manchurian countryside. After the war, the Nationalists appeared to have superior resources. They were recognized as the legitimate government. Nationalist party assassinated Wen (pg. 326) which showed their desperation to retain power. Taiwan suffered worse and they rioted in protest, 1947, but the Nationalist government responded with brutal and bloody repression. The government couldnââ¬â¢t stop the inflation and people had to carry bundles of paper money to shop. The CCP had a disciplined and well-organized political and military leadership. In Jul 1947, communist armies attacked several fronts in Northern China. Lin Biao completely routed the Nationalist party in 1948. In 1949, Nationalist generals surrendered Beijing and Tianjin. Mao Zedong formally proclaimed the establishment of Peopleââ¬â¢s Republic of China. * Japan: The Occupation Ends and Means The Occupationââ¬â¢s mission was to demilitarize Japan and turn the country into a peaceful and democratic state which was under the authority of the Far Eastern Commission in Washington. Japanese government continued to function, but according to the Occupation authorities under MacArthur, Supreme Commander for the Allied Powers. Occupation supplied food and medical supplies and US become seriously concerned with rebuilding Japanese economy is 1947. People were purged, half of them from the military. Outside of Japan, people were tried and sentenced to death. Tojo as well who headed Japanââ¬â¢s wartime government. The emperor was not charged and was pressured to substitute a more open lifestyle like British monarch. Under the new constitution he became a symbol of the nation. Constitution went into effect May 1947.
Tuesday, July 30, 2019
Powder by Tobias Wolff Essay
One of the most renowned American writers, Tobias Wolff is known mainly for his work on the memoir, and short stories. He was part of a new wave of writers, including Andre Dubus and Raymond Carver, who ushered in a novel style of fiction writing, which is all at once real yet incredible, grounded yet detached, but always engaging. Wolff wrote his short story ââ¬Å"Powderâ⬠as part of his 1996 collection entitled The Night In Question. There are only two major characters in the storyââ¬âthe teenaged narrator and his father, and everything takes place within the area of Mount Baker, a skiing resort. The fact that the boyââ¬â¢s parents were on the verge of divorce is established early on, and some of the implied reasons lie in the fatherââ¬â¢s character. Three descriptions were used in the first few paragraphs of the story that alluded to the fatherââ¬âââ¬Å"he had to fight for the privilegeâ⬠, ââ¬Å"he wouldnââ¬â¢t give upâ⬠, and ââ¬Å"he was indiff erent to my frettingâ⬠. These three descriptive phrases convey a picture of a man with an aggressive nature, and would always pursue what he wants; this is proven by his keeping the flashy Austin-Healey, by insisting on taking his son to a club, and by being focused on bringing him homeââ¬âso as not to get his wifeââ¬â¢s ire, for he believes they would still be able to patch things up. At the end of the story, it is the son himself who uses several adjectives on his fatherââ¬âââ¬Å"rumpled, kind, bankrupt of honor, flushed with certainty. He was a great driver. All persuasion, nor coercion.â⬠After reading the story in its entirety, one would be able to associate the seemingly carefree and spontaneous characterization of the father to his being a man of gentle manner, yet gregarious tone; what his son lacked in youthfulness and spirit, he completely made up for. The methods of character development, as applied to the story, further examines the contrasting personalities of father and son: Narrative summary without judgment. While the father is almost explicitly judged through specific mentions of behavior and mindsets, the son, being the narrator, only reveals his true character of being methodical and systematic at the end of the story. The reader will only assume him to be a young boy easily influenced by his father. Narrative description with implied or explicit judgment. Exactly the way the father is discussed, as mentioned previously. Surface details of dress and appearance. For the father, the main points would be his Austin-Healey, and his sonââ¬â¢s mention of his being rumpled, kind, and forty-eight years old. The son is later described, through his system with his clothes hangers, as being forward-thinking and methodical, and not exactly one who would take risks. Characterââ¬â¢s actionsââ¬âwhat they do. The father is eager, spontaneous, and has no regard for rules, except when already in dire straits. Characterââ¬â¢s speechââ¬âwhat they say. Using words like ââ¬Å"Vamanosâ⬠, and ââ¬Å"Buck upâ⬠shows the casual personality of the father, and the boyââ¬â¢s prim manner and speech validates his guarded nature. While the fatherââ¬â¢s character seems to be the more ââ¬Å"exploredâ⬠of the two, it simply shows their contrasting personalities, and how unusual these are for a child and an adult. But in truth, the concept of fresh powder represents the boyââ¬â¢s realization about new and uncharted territories far beyond his always-prepared itinerary. Without his father, who believes in persuading people to given in or help, the boy would have never seen how things are not always measured and studied, and that often one has to see where the road will take him.
Monday, July 29, 2019
Understanding the phenomenon of shale gas revolution Research Paper
Understanding the phenomenon of shale gas revolution - Research Paper Example The cost of gas is projected to go down as there is surplus production. The future of the revolution depends on proper policies to solve any crisis and bringing balance in regard to energy prices that will be suitable for both the countries experiencing the revolution and the major oil and gas producers. In the recent past, the energy sector has witnessed some technological advancement aimed at resolving the global energy crisis. Research beyond the current crude oil reserves has led to significant discoveries such as shale oil deposits that have added to the annual increase in production of oil and gas. These developments are thought to play a significant role in the global oil markets and energy at large. The technology is prevalent in the North American continent that is United States and Canada, who are exploiting the venture in large scale. Shale gas is said to be one of the greatest energy revolutions of all time. Although the technology is in its infancy stages in America, implications both political and economic go beyond its borders. Adversaries and allies of the United States will experience different effects due to the diversity of ways through which the technology will influence international energy markets and politics. Although there are a lot of uncertainties regarding the global energy markets, shale technology offers a great deal of ways that will enable America take advantages in the geopolitical sphere. The promise and potential of shale gas production are relatively high with the ability to impact substantially on the market economy. Shale gas presents a cheaper source of non-renewable energy that is environment-friendly, and most plants are substituting coal for it. However, the potentiality of shale technology depends on the primary producers that are Canada and the United States who are currently the supply hub. The
Sunday, July 28, 2019
EB Essay Example | Topics and Well Written Essays - 1500 words
EB - Essay Example on the Scarborough campus. This, we hope, will provide a major step forward in the development of student facilities. This research also serves to fulfil partial requirements of my degree programme. 1.2 Background to research The Scarborough campus does not currently have a school bus and so the implementation of such a system would help to alleviate some of the problems that students currently face students in their efforts to arrive on the campus in time for classes. A properly run bus system would reduce lateness and provide a convenient means of getting from home to the campus. The bus will also help in transporting students between Scarborough campus and the main campus. However, the system would only make sense if it is feasible 2.0 Research Description and Methodology 2.1 Plan of research The research is in the form of a survey. ... The questionnaire was designed to allow for five alternative choices in most cases. There was only one question requiring a yes or no answer. Only two questions were designed using the Likert scale with choices ranging from 1 to 5 with 1 being the weakest/lowest and 5 being the strongest/highest. Delanshire & Petrosky, 1998 indicates that: ââ¬Å"Whenever you use checklists or rating scales, you simplify and more easily quantify peopleââ¬â¢s behaviors and attitudes. In the process you may lose valuable information.â⬠(qtd. in Leedy and Ormrod, 2005, pg187). However, it is hoped that no valuable information is lost here. 2.2 Discussion of methods The research looks at key variables that will help determine the feasibility of the bus system such as where students live, the circumstances under which they would want to take a bus, how often they travel by bus, get an idea of the timetable which would suggest frequency of use and the price that students consider reasonable. These questions were derived from the consideration of factors that would make the system feasible. If there are no students who are in need of the service, it will not be workable. 3.0 Data Collection 3.1 Data Collection procedures Data was collected with the use of questionnaires which were emailed to the respondents. After they were returned the data was collated and analysed using graphs and charts. The questionnaire is included in the Appendix. 3.2 Sampling Method The sample was not randomly selected because of the time constraint. It was administered to classmates and a few other students. Therefore, we know that the sample chosen was biased. 4.0 Findings 4.1 Overall Findings Questionnaires were emailed to a total of 50
Saturday, July 27, 2019
Interview conduction and job description Research Paper
Interview conduction and job description - Research Paper Example Potential candidate must be matched against the requirements of the job. This step leads to the third step which is recording and summarizing the information of each candidate. Once the information for each candidate has been recorded, appointments of date and time for interview should be scheduled. After these steps are done, relevant potential candidates are notified about the interview time, date and place. Questions which are to be asked should be as short as possible. The questions should be framed in such a manner that they have a good mix up of both close-ended as well as open-ended questions. The questions should be specific, free from bias and ambiguity. It is necessary to draw a line between those questions which should be asked and those which should be discussed about. While conducting interviews, it is advisable for interviewer to give time to the respondent to answer the questions and be a good listener. Interviewees are also supposed to be calm and confident during interview. It is not at all necessary to panic or getting worried. (Cuomo, n.d.) Most of the interviewers waste a lot of time in filing out the applications or resumes. In some cases, it takes thirty to sixty minutes to do so. Therefore, it is necessary to shorten the applications. In order to cope up with this issue, interviewers need to allow technology for speeding up the process. Applicants can be asked to fill out their information on companyââ¬â¢s site. (BridgeWater State University, n.d.) At the beginning of the interview, both interviewee and interviewer should have little conversation so as to relax the environment from any stress and nervousness. It is necessary to ease up the atmosphere so that there is no reluctance and hesitation between the two parties. Some casual conversation is essential to relax both, the interviewer and the interviewee. Applicants should be asked only relevant questions and unnecessary conversation must be
The Royal National Institute for Blind People (RNIB) Assignment - 1
The Royal National Institute for Blind People (RNIB) - Assignment Example The present research has identified that the RNIB need donations to stay afloat.à How the organization goes about getting that support is as yet unknown, but it is hoped that the RNIB will read these recommendations and take them seriously enough to consider implementing all, if not a few of, the suggested media campaigns.à These various campaigns span a wide variety of strategies in order to get the most profitability with regard to how donations are collected. That having been said, it is hoped that several of the strategies to be discussed in this report will be ultimately implemented. Hopefully, these strategies will alleviate some key financial stresses. The general role of advertisingââ¬âin other words, the advertising campaign that will be conductedââ¬âwill be focused on improving the livelihoods of several people who use the RNIB in order to provide the services and materials as blind or partially sighted people. ââ¬Å"The Royal National Institute for the Blind (RNIB) is the leading charity providing practical support, advice, and information for the one million blind and partially sighted people in the UKâ⬠. In order to generate revenue, basically, the RNIB needs to conduct some sort of marketing campaign, which will be discussed further in other sections. Generally, however, the role of advertising is to convince the public that funds must be solicited, and elicited, in order to keep its platform and variety of services available for the portion of the public which is blind or partially sighted. Some of the key messages that must be presented are that: a) this is a good cause which benefits the disabled or partially disabled residents of the UK; b) in order to continue providing their clients service, they need funds; and c) without additional funding, the RNIB would probably not be able to continue servicing their clients. That is the message to prospective customers. The messages to current consumers of RNIB is that they must get on the bandwagon in order to promote RNIB or there are going to be serious consequencesââ¬âone of those consequences, namely being, that RNIB could potentially shut its doors forever without receiving adequate support.
Friday, July 26, 2019
Use of Financial Ratios Essay Example | Topics and Well Written Essays - 1000 words
Use of Financial Ratios - Essay Example The paper is an attempt to analyze the accuracy of the statement of Lev and Sunder using some evidences taken from real world, especially by doing the cross sectional analysis of financial ratios. Use of Financial Ratios Financial ratios are used to measure a companyââ¬â¢s financial condition or to analyze between two companiesââ¬â¢ financial condition. All the stakeholders of the company have interest in companyââ¬â¢s future, that is how the company would perform in the short term or long term future, how much it is secure to invest in the company, what type of change should be introduce so that the company can perform better. When an investor wants to take the decision to invest money, certainly he wants to invest it in the most effective company, the decision he can take by using the financial ratio analysis along with other type of analysis like qualitative analysis or other type of quantitative analysis. Critical Analysis Ratio analysis is a very widely used tool for analyze the financial stability of a firm. But there are certain problems arise when the analyst donââ¬â¢t take the associated factors in consideration. When the analyst is doing the performance analysis of two companies, they should remind that two companies can follow two different accounting policies. There is no single accounting standard which is being followed by the companies all over the world. (Fischer, Taylor and Cheng, 2008, p.505). The taxation rules of different states, different countries vary over the world. The inflation over the world is different. A multinational company has to face different taxation policy, different inflation over the world. So when a researcher is analyzing the performance of a company using ratio analysis, he should take these factors in account. There are also technical factors associated with the analysis. Many statistical tools which are being used in ratio analysis are based on the assumption that the data are normally distributed, but in reality that doesnââ¬â¢t happened. For identifying the financial indicators specifically for Critically Access Hospitals the Flex Monitoring Team used 114 financial ratios as their part of research. But they found many problems when research about the industry, like Hospitals with negative current Assets or negative current liabilities was excluded from the calculation of median, but that should be i ncluded when researching about the liquidity of the industry (Flex Monitoring Team, 2005, p.17-18). A research study was performed by taking 66 listed Malaysian firmsââ¬â¢ data for the period 1980 to 1996. The forms were taken from 3 sectors industrial sector, mixed industry and combination of industrial and property sector. From the research it has been seen that only current asset percent was conformed to normal distribution. For doing the ratio analysis effectively three type of transformation techniques were used namely square, square root and natural log. When the square and square root property were used they were found as not effective, because the variables of the ratio analysis are not normally distributed. But natural log technique is proved effective by the researcher as the process considers that the data available is not normal. The researcher proved through the research that when a ratio analysis is being performed to analyze the performance of a company or comparab le analysis between two companies is done then they should address the proportionality effect on the ratioââ¬â¢s normality (Sori et al., 2006, p.71-81). From a survey done on U.S.A. firms it is clear a ratio can
Thursday, July 25, 2019
How Religions Impact Americans Politically, Socially and Economically Essay
How Religions Impact Americans Politically, Socially and Economically - Essay Example Statistics released by the British Broadcasting Corporation (BBC) in 2012 have shown that out of the worldââ¬â¢s total population, 59 percent is religious, and, the United States, unlike several other Western countries, remains a religiously overwhelming society. This paper will discuss the political, social and economical impact religion has had on the American society, with specific focus on Christianity, Judaism and Hinduism. As a nation, the United States founding was on religion. Majority of the American population is Christian, predominantly 30 percent White Evangelical Protestants, 20 percent Liberal Protestants and 8 percent African-American Protestants. 2 percent practices Judaism and 0.5 percent are Hindus. Most of the non-Christian religions in the United States found their way there after the 1965 Immigration and Nationality Act that removed restrictions that previously limited foreigners who could immigrate. As portrayed by Farlee (1999), the American society has grow n into a successful multi-cultural, multi-ethnic and multi-religious nation. From the nationââ¬â¢s founding fathers to present day presidents, the American leadership has portrayed the significance of redirecting public policy towards enhancing the future health of the nation in religion, especially Christianity, though not to dictate that it is a Christian nation. Many political and social goals have been achieved through the practice of religion, even if it was indirectly. Christianity and the influence of Jewish ideas are clearly manifested in the fundamental political framework of America, as is evident in the opening statement of the Declaration of Independence. It is declared, just like in the bible, that men were all created equal and endowed with unalienable rights including life and the pursuit of liberty and freedom. Even from the early days of the Puritan settlers, the scripture determined the legislation. As concurred by Ballo (1976), they believed that the scripture held the moral rules for the government and direction of humans in their duty to fellow man and God and subsequently adopted a legal code with 79 statutes, of which half bore biblical references. The Republican coalition and the pact with the Christian Right were splintered by President Obamaââ¬â¢s election in 2008. This opened up the opportunity to the new coalition between the new evangelical Christians and the Democratic Party. Although the new evangelical Christians identified themselves as progressive and politically moderate, it was evident from the 2008 poll that the Democratic Party had openly adopted Christian foundations. This showed its effect in another unexpected manner when previously separate religious groups joined forces based on political allegiances to fight the unbiblical gay marriage. This saw the Mormons and conservative Catholics come together to front the Californiaââ¬â¢s Proposition 8 that fought gay marriages, also including international policy among Jews and Protestants. Although the governmentââ¬â¢s religious connections have been growing, causing a slight relationship sway with the Protestants, they (Protestants) remain intact in their presumption of the politics of the US, with their visions still upheld regarding gender and sexuality. Quite notably, Hinduism has no significant impact on the American political system as much as do Christianity and Judaism, but might be remotely playing smaller roles through the strong presence of Hinduism in the American
Wednesday, July 24, 2019
Lit 8a Essay Example | Topics and Well Written Essays - 500 words
Lit 8a - Essay Example Many critics point out that Dr. Seussââ¬â¢s characters have enjoyed the pleasure of life along with thrill in misbehaving. In his online article titled Dr. Seuss: American Icon, Philip Nel shares his own views about Dr Seussââ¬â¢s works. He says, ââ¬Å"His work was a rational insanity that exhibited joyous anarchy and a lifelong thrill in misbehaving.â⬠(Nel). After reading these comments one can see that Dr. Seussââ¬â¢s works are mainly for children. Many of his books provide strong moral messages example The Cat in the Hat and The Sneeches which discuss the stories of children. The article entitled Creating Drama with Poetry: Teaching English as a Second Language through Dramatization and Improvisation gives a brief summary of the relevance of dramatization and improvisation in second language classroom. There are different ways for adopting these methods in the class room. Dramatization of poetry helps the students to acquire the various aspects of language such as linguistic, syntactical and conceptual. There are several classroom techniques which are useful for teaching poetry. Giving the students model for pronunciation, stress, rhythm and expression is one. Motivate them to create conversation and interaction. To create workshops for drama in classroom is another important way Picture book is a short demonstration book, where the lessons to be taught are presented in the form of pictures. Picture books are highly helpful for children. These include alphabet books, books about different seasons, books about colors and counting books. Picture storybooks reveal a story with the help of suitable pictures and illustrations. Susan Hall gives enough clarifications about the definition of picture storybook. He says, ââ¬Å"The words and pictures ideally share in revealing the story so that what is not said in the text is shown in illustration.â⬠(Hall). The following storybooks are prescribed for children.
Tuesday, July 23, 2019
Lawsuits against Counselors Essay Example | Topics and Well Written Essays - 500 words
Lawsuits against Counselors - Essay Example In 2001, a high school counselor was sued because a student claimed he was told a particular English class was accredited, but he later lost his scholarship because it wasn't. The guidance counselor denied giving the student that advice, but the courts ruled in favor of the student. Karla Scoon Reid's news report reads, "A high school counselor can be sued for dispensing academic advice that has an adverse effect on a student." In this instance, the counselor could have saved himself the trouble by double-checking to make sure the class was properly accredited, especially since it was new to the high school's curriculum. With recent allegations having come forth regarding Catholic priests and molestation/rape, it is no wonder that failure to report child abuse is a huge faux pas. Child abuse charges that need to be reported are not only ones of a sexual nature, but also physical abuse. As well, clergy counselors are especially susceptible. A website report on clergy counselors reads, "At least nine states have permitted adults who were abused as children to sue clergy counselors (para. 1)." Since each state has different laws, counselors who are made aware of child abuse need to stay updated on exactly what allegations need to be reported, and which officials are appropriate to contact in each specific case. The most common cause of lawsuits against counselors, perhaps, is failure to prevent suicide.
Monday, July 22, 2019
Deinstitutionalizing the Mentally lll, Blessing or Curse Essay Example for Free
Deinstitutionalizing the Mentally lll, Blessing or Curse Essay The deinstitutionalization of the mentally ill was originally and idealistically portrayed as a liberating, humane policy alternative to the restrictive care in large state supported hospitals. It was supposed to help these individuals regain freedom and empower themselves through responsible choices and actions. Due to many funding issues, stiff opposition from communities, and ill-equipped patients, who are unable to live independently, this idealized program, has not always been a blessing for the communities or the patients. In the early 1960s, President John F. Kennedy signed into law a bill that began the movement known as deinstitutionalization. The purpose of the new law was to put an end to the tendency to warehouse people with mental illnesses, as well as those with developmental disabilities, including the mentally and physically handicapped. The idea was to move the less severely mentally ill from those large institutions into the community, where local treatment centers would be established to provide them with medical, psychiatric, and social support they need to be able to live and function. see more:smartphones boon or bane Some believe that deinstitutionalization has been and continues to be successful. Perhaps one of the brightest spots of the effects of deinstitutionalization is that the mentally ill have gained a greatly increased measure of liberty (Curtis, 2008). Some persons, despite their illnesses, have realized a certain degree of normalization in their daily activities. Some live independently, and some are productively employed, achievements that were relatively rare in the days before deinstitutionalization. For these people, deinstitutionalization must be regarded as a positive development (Warner, 1995). Deinstitutionalization, which has now become a synonym for neglect, was supposed to be about creating a new system of services and supports that would allow people with mental illness and mental retardation to thrive in their communities outside of hospital settings during all of the times when they did not need hospital services (Sheth, 2009). An estimated 4. 5 million Americans today suffer from the severest forms of brain disorder, schizophrenia and manic-depressive illness and out of 4. million 1. 8 million, or 40 percent are not receiving any treatment on any given day, resulting in homelessness, incarceration, and violence; one of the reasons for this condition is a failure of the deinstitutionalization policy (Fact Sheet, Treatment Advocacy Centre).? The U. S. Department of Justice estimates that over a quarter of a million mentally ill individuals are currently incarcerated in the U. S. state and federal prison system constituting between eight and 17 percent of the entire prison population (Martin, 2011). The deinstitutionalization policy, which has been improperly implemented, is acting like a misguided missile, causing the helpless and defenseless inmates of the mental hospitals to beg and roam on roads and footpaths; to take refuge in shelter homes and beggarââ¬â¢s homes; to starve on streets and eat from garbage bins; they are jeered in society and physically, verbally and sexually assaulted in alleys; they languish in jails and suffers in prisons; They shiver in cold and simmer in heat; they sleep on a bed of earth with a blanket of sky. We have shifted problems of mental hospitals to the streets, jails and shelter homes. While making backyards of our mental hospitals beautiful, we have made our streets ugly. The process of deinstitutionalization has turned deadly. There seems to be some truth in a saying that deinstitutionalization caused people to die with their rights on (Sheth, 2009). The deinstitutionalization movement of the mentally ill had a noble aim, but failed to achieve it. The solution is complicated but it is not however, unattainable. Train the police officers and emergency responders on how to identify the mentally ill patients and direct them into available treatment facilities. The government can also fund jail and prison programs that screen, evaluate and treat mentally ill inmates. Establish mental health courts, more mental hospitals with adequate staffing, start more day care centers, and have more adequate affordable housing. These solutions, of course, all require funding from a government with spending that is already out of control and on the brink of bankruptcy. But the truth is, by helping the seriously mentally ill, we help ourselves.
The ruling of the U. S. Supreme Court Essay Example for Free
The ruling of the U. S. Supreme Court Essay The ruling of the U. S. Supreme Court in Beth Ann Faragher v. City of Boca Raton, 524 U. S. 775 (1998) laid down precedent on the application of the Civil Rights Law as it addressed a womanââ¬â¢s quest for justice. Having accused and proved her two supervisors liable for sexual harassment, Faragher appealed the lower courtââ¬â¢s ruling exculpating the City from liability. The decision, penned by Justice Souter, delved at length on the theories propounded on the case and sought to define the parameters by which an employer may prove non-liability. This study will be confined to a discussion of the material facts and issues vis-a-vis the liability of the respondent employer insofar as it touches upon the reasonable care doctrine, reasonable person standard, and reasonable victim standard. The facts of the case narrated herein are taken from the Supreme Court decision. A college student, Beth Ann Faragher worked part-time as lifeguard for the Marine Safety Section of the Parks and Recreation Department of the City of Boca Raton, Florida between the years 1985 and 1990. She was under the immediate supervision of Bill Terry, David Silverman, and Robert Gordon. During the hours of work, Terry and Silverman subjected Faragher and the other female lifeguards to acts of sexual harassment. Faragher complained to no one, although she did mention it to Gordon whom she respected, but he did nothing. Two months before Faragher resigned, a female lifeguard formerly employed by the City wrote the City Personnel Director complaining that she and her co-workers had been harassed by Terry and Silverman. The City ordered a probe and upon finding the two guilty of improper behavior, reprimanded them and made them choose between suspension without pay or forfeiture of annual leave benefits. Faragher resigned in June 1990. In 1992, she brought an action before the U. S. District Court for the Southern District of Florida against Terry and Silverman alleging that they created a ââ¬Å"sexually hostile atmosphereâ⬠at work which amounted to a violation of Title VII of the Civil Rights Law. She likewise impleaded the City on the ground of its agency relationship with the two men. (Faragher, 1-2) Faragher alleged that Terry and Silverman subjected her and the other female lifeguards to ââ¬Å"uninvited and offensive touchingâ⬠, lewd remarks, and language offensive to women. She told the Court about Terryââ¬â¢s alleged statement that he would never promote a woman to the rank of lieutenant. Silverman, on the other hand, allegedly asked her either to date him or clean the toilets for a year. It was established that Terry could hire personnel(subject to approval by higher management) counsel or orally reprimand subordinates and have the same recorded. Lifeguards and their supervisors observed a paramilitary chain of command: the former reported to the lieutenants and captains who in turn reported to Terry. The latter was under the supervision of the Recreation Superintendent who reported to the Director of Parks and Recreation who answered to the City Manager. (Faragher, 2) The City had adopted a policy on sexual harassment which the City Manager disseminated to employees by memorandum. This was revised in May 1990 while Faragher was still in the service but it did not reach the employees of the Marine Safety Section, thus, the respondent supervisors and many lifeguards were not aware of it. (Faragher, 2) The District Court ruled in favor of Faragher, concluding that Terry and Silverman were guilty of harassment that altered the conditions of their employment, resulting in an abusive working environment. Likewise, it found the City liable on three grounds. First, the City was deemed aware of the harassment because of its pervasiveness. Second, the City was liable under the principle of agency, i. e. , the act of the agent is the act of the principal. Third, Gordonââ¬â¢s knowledge of the harassment and his inaction was a further basis to impute liability to the City. (Faragher, 3-4) The District Courtââ¬â¢s decision insofar as the City is concerned was reversed on appeal. The Court of Appeals of the Eleventh Circuit, through a panel of justices, ruled that the City could not be held liable on the basis of the agency principle, that Terry and Sullivan did not act within the scope of their employment when they committed the acts complained of, nor did the City have constructive knowledge thereof. The Court of Appeals sitting en banc adopted the conclusion of the panel. Its ruling was based on an earlier decision of the Court of Appeals in Meritor Savings Bank, FSB v. Vinson, 477 U. S. 57 (1986). In that case, the Court found three conditions under which an employer may be held indirectly liable for hostile environment sexual harassment by a superior: ââ¬Å"(1) if the harassment occurs within the scope of the superiorââ¬â¢s employment; (2) if the employer assigns performance of a nondelegable duty to a supervisor and an employee is injured because of the supervisorââ¬â¢s failure to carry out that duty; or (3) if there is an agency relationship which aids the supervisorââ¬â¢s ability or opportunity to harass his subordinate. â⬠(Meritor, 6). As to the first, the Appeals Court held that the acts of the supervisors were ââ¬Å"frolicâ⬠: unrelated to their duties and were done for their own personal ends. As to the second, it was ruled that the mere existence of an agency relationship between the supervisors and the City did not give rise to liability on the latterââ¬â¢s part as there was no showing that such relationship assisted them in perpetrating their acts. As to the third, the Court found no constructive knowledge on the part of the City as regards the harassment. In fine, the Supreme Court disregarded the arguments of the Court of Appeals and found in favor of Faragher. (Faragher, 5) As argued by the District Court, the act of the agent is presumed the act of the principal. In applying this rule the District court held that ââ¬Å"an employer is strictly liable for a hostile environment created by a supervisorââ¬â¢s sexual advances, even though the employer neither knew nor reasonably could have known of the alleged misconduct. â⬠This automatic liability rule is challenged by those who claimed that constructive knowledge may be substituted for direct knowledge. For example, a supervisor who makes decisions that tend to affect the economic status of an employee is deemed a proxy of the employer which makes the latter liable thereon. Also, personnel actions of a supervisor like promoting, firing, hiring and the like which discriminate against employees would make his employer vicariously liable for those acts. In a sense, a supervisor is considered always assisted by the employer by virtue of his superior position in the workplace. A co-worker may easily brush off the sexual advances of an equal; not so with a supervisor. Thus, Faragher contended` that the power held by Terry and Silverman over her enabled them to carry on their harassment with impunity. Some courts were of the view that some standards were needed in those cases where there is no clear showing that the employer had knowledge, constructive or otherwise, of the harassment committed by his supervisors. In Faragher, it was evident that the City could not have aware of the intermittent sexual abuse committed by Terry and Sullivan. Gordon did not inform any of his superiors about Faragherââ¬â¢s problem. (2). Moreover, the City through the Personnel Director had issued a memorandum informing employees about the procedures to bring their complaint against any sexual harassment. Faragher had informed Gordon about her plight, albeit in an informal way. (Faragher, 2) Was the City liable? Meritor laid down the ruling that neither ââ¬Å"the existence of a company grievance procedure nor the absence of actual notice of the harassment on the part of upper management would be dispositive of such a claim; while neither might be relevant to the liability, neither would result automatically in employer immunity. â⬠(6). The Court further stated that the absence of notice to employer did not necessarily insulate that employer from liability. However, it declined to give a definitive rule on employee liability ( 7). Vicarious liability is supported by the view that employers generally derive benefit from the service of their supervisors; thus they should bear the risk of any wrong arising from their employment. The employer should likewise answer for any damage sustained by a common employee on the principle that the latter worked for the employerââ¬â¢s benefit; consequently, the employer must assume such risks on the basis of equity and fairness. Notwithstanding these views, it was held in Faragher that one more condition was needed to satisfy the evidentiary requirement for a finding of vicarious liability. Two alternatives were given by the Court: ââ¬Å"(1) require proof of some affirmative invocation of supervisory authority by the harassing supervisor, or (2) recognize an affirmative defense to liability in some circumstances, even when a supervisor has created the actionable environment. â⬠(Faragher, 16) The first alternative, as the Court itself admits, may be impractical in most instances since no supervisor is presumed foolhardy enough to court harassment suits by announcing his threats. As to the second, the employer is afforded the opportunity to prove that he ââ¬Å"had exercised reasonable care to avoid harassment and to eliminate it when it might occur, and that the complaining employee had failed to act with like reasonable care to take advantage of the employerââ¬â¢s safeguards and otherwise to prevent harm that could have been avoided. â⬠To invoke this defense, the employer must show that he had taken reasonable care or exercised foresight to prevent sexual harassment in the premises, knowing by human experience that such incidents are likely to occur, as in this case where the men held sway over the women by reason of their superior position. This affirmative defense has two elements: ââ¬Å"(1) that the employer exercised reasonable care to prevent and correct promptly any sexually harassing behavior, and (2) that the plaintiff employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise. â⬠(Faragher, 18). The doctrine of reasonable care mandates that every person shall conduct his affairs towards his fellowmen with sufficient care as any reasonable person would do in any given circumstance, failing in which, he may be held liable for any injury that may be sustained by others so affected by his actions. What is ââ¬Å"reasonableâ⬠is a question of fact most often left to the judgment of the courts. This principle is akin to that of tort law which governs the liability of masters over the acts of their servants. It adopts the applicable principles of common law and those governing quasi-delict which impute liability to the employer for the negligence of his employees, the vehicle owner to the driver, the master of the household to the helper. The owner of a vehicle, for example, becomes the defendant in a civil action for damages if his driver inflicts damage to a third party. His defense would be that he exercised due diligence in hiring his driver, such as requiring him to show proof that he had not been in any accident and had no derogatory record on matters of driving. According to Wikipedia, ââ¬Å"the reasonable man or reasonable person standard is a legal fiction that originated in the development of the common law. The reasonable person is a hypothetical individual whose view of things is consulted in the process of making decisions of law. â⬠(no indicated page) Minnesota adds: ââ¬Å"Besides being an objective standard, the ââ¬Ëreasonable personââ¬â¢ standard is an adult standard. â⬠(home page). The reasonable person standard applies as well to the purported victim. The victim must prove he or she was not remiss in doing what a reasonable person would have done in his or her place. By analogy, in criminal law, rape victims must prove they put up sufficient defense to prove that the sexual act was committed forcibly against their will. The reasonable victim standard is that applied in the case of the person wronged. Faragher did not avail herself of the grievance procedure prescribed by the City as mandated by the Equal Employment Opportunity Commission(EEOC), as she ââ¬Å"was completely isolated from the Cityââ¬â¢s higher managementâ⬠during the period of harassment. (Faragher, 19). The term ââ¬Å"reasonable victimâ⬠may have evolved from the realization that in determining what constitutes a reasonable person standard, gender must be taken into account. According to Hamilton, the term ââ¬Å"reasonable womanâ⬠was used when a Florida District Court, ruling in Robinson v. Jacksonville Shipyards, Inc. called for a ââ¬Å"sexually hostile work environmentâ⬠to be evaluated through the eyes of a ââ¬Å"reasonable woman. â⬠Years later, the U. S. Supreme Court used a ââ¬Å"reasonable personâ⬠standard in deciding Harris v. Forklift Systems, Inc. (2) According to Alexander: Applying the ââ¬Ëreasonable victimââ¬â¢ standard not only helps plaintiffs, but also helps the justice system as a whole by defeating societal stereotypes perpetuated by the application of the ââ¬Å"reasonable personâ⬠standard. By allowing defendant employers to claim an affirmative defense to the sexual harassment claims of their employees, the court would help protect cautious, law-abiding employees from frivolous claims. The second prong of the defense would require employees to report sexually harassing conduct to their employers promptly, and at the same time, require employers to eliminate harassing conduct in the workplace swiftly or risk discipline in court. (home page). Faragher is a landmark decision in that it gave the definitive rule to determine employer liability not given by the Court in Meritor. The problem of sexual harassment may never be eradicated, human beings being as they are, but a concerned employer with forethought, through a competent human resource department, may considerably reduce its occurrence at the workplace. From Faragher, human resource departments should take cognizance of the importance of constant meaningful dialogues between and among employers and their personnel workers and supervisors alike to immediately stop whatever harassment are being committed against members of either sex. Finally, a continuing education program aimed at removing gender bias and sexual prejudice, encouraging victims to speak out and assert their rights or seek redress before the proper forum, combined with the continuous monitoring of workplaces and giving employees reasonable access to legal assistance, are positive steps towards this end. WORKS CITED Alexander, Kamla, ââ¬Å"A Modest Proposal: The Reasonable Victim Standard and Alaska Employersââ¬â¢ Affirmative Defense to Vicarious Liability for Sexual Harassmentâ⬠. Alaska Law Review. Cited 17 Alaska L. Rev. 297 http://www. law. duke. edu/journals/alr/ Alexander Hamilton Institute Inc. , ââ¬Å"A Legal Look at the ââ¬ËReasonable Victimââ¬â¢ Standardâ⬠Personnel Legal Alert. August 2, 2004, Vol. 16, No. 5 http://www. ahipubs. com/samples/08-02-04pla. pdf. Meritor Savings Bank, FSB v. Vinson 477 U. S. 57 http://caselaw. lp. findlaw. com Minnesota Office of Citizenship and Volunteer Services, ââ¬Å"Planning It Safe: How to Control Liability and Risk in Volunteer Programs, Revised Edition. 1998 http://www. energizeinc. com. art/html Supreme Court of the United States, ââ¬Å"Beth Ann Faragher v. City of Boca Ratonâ⬠524 U. S. 775 http://www. national center. org/FaraghervBocaRaton. 98. html Wikipedia, ââ¬Å"Reasonable Person Standardâ⬠http://en. wikipedia. org
Sunday, July 21, 2019
Acute Myocardial Infarction and Periodontal Disease
Acute Myocardial Infarction and Periodontal Disease Research Findings The study examined the association between acute myocardial infarction and periodontal diseases using cross sectional design. The analysis was carried out using the SPSS/PC Windows version 21.0 software package (IBM, Inc.). The sample size taken for the study was 80 (Cases=40, Control=40). The bivariate association between the studied variables, acute MI and periodontitis (dichotomized) was analyzed with the appropriate test. A significance level of pâⰠ¤0.05 was considered significant and the odds ratios with 95% confidence intervals were calculated. Further, conditional logistic regression analysis/cox regression analysis (1:1 matched pairs) was used to assess the independent contribution of periodontal diseases to the risk of acute myocardial infarction and also to find the relationship between AMI and other possible explanatory variables. The risk factors such as tobacco habit, smoking, dietary habits, family history of diabetes, were forced into the model. The following secti on presents the results. Descriptive Statistics and Preliminary Analyses Association between acute myocardial infarction and study variables. The table below presents the association between Acute Myocardial Infarction and study variables. The results showed that odds of outcome (AMI) were significantly higher in subjects with periodontitis, smoking habits, hypertension and mixed dietary habits. Out of the total 80 patients, the majority of the periodontitis patients (82.5%) were present within the case group (AMI patients) (p=0.026). Similarly, the prevalence of smoking (52.5% vs. 27.5%, p=0.031) and hypertension (52.5% vs. 47.9%, p Table 6:à Association between Acute Myocardial Infarction and study variables *p Association between periodontitis and study variables. The table below presents the association between Periodontitis and study variables. The results showed that odds of outcome (periodontitis) were significantly higher in subjects with smoking habits, hypertension and alcohol drinking (p Table 7:à Association between Periodontitis and study variables Conditional Logistic Regression Analysis Using Cox Proportional Hazard Model Following the preliminary analysisââ¬â¢ cox regression analyses were used to assess the independent contribution of periodontal diseases to the risk of acute myocardial infarction and also to find the relationship between an AMI event and possible explanatory variables. To control the effects of multiple potential confounders, multivariate model were also fitted by modeling periodontitis as a time varying covariant in a model. Cox proportional hazard analysis allowed the researcher to include the predictor variables (covariates) one by one into the subsequent models. This provided estimated coefficients for each of the covariates and allowed the researcher to assess the impact of multiple covariates in the same model. We can also use Cox regression to examine the effect of continuous covariates such as BMI. The following recoding was done to examine the association between AMI and periodontitis. Socio economic status=0 (Reference category): Lower; 1=Upper Lower; 2=Lower middle; 3=Upper middle; 4=Upper: Family history=0 (Reference category): No; 1=Yes; Exercise=0 (Reference category): Yes; 1=No ; Hyper tension=0 (Reference category): No; 1=Yes: Diabetes=0 (Reference category): No; 1=Yes: Dietary habit=0 (Reference category): Vegetarian; 1=Mixed: Smoking habit=0 (Reference category): Non-smoker; 1= Former smoker; 2=Smoker: Smokeless tobacco habit=0 (Reference category): Non-users; 1= Former user; 2=Current u ser: Alcohol drinking=0 (Reference category): Non-drinker; 1= Current drinker; 2=Irregular abstainer: Marital status=0 (Reference category): Unmarried; 1= Married; 2=Divorced. The conditional logistic regression estimates the odds ratio, and an exact 95% confidence interval. Table 3, below presents the association between AMI and Periodontitis using Cox regression. Table 8:à Cox Regression Dependent variable: Acute Myocardial Infarction Conditional logistic regression analysis outcomes indicated the presence of a significant association between AMI and periodontitis (Beta=1.358, p= .039 In all the stages, for regular exercise the beta value is negative which means it is a protective factor or is inversely related as acute myocardial events, however this association is not statistically significant to report. Statistical Analysis of Other Clinical Parameters (DMFT, CPI and LOA Scores) Test for normality. To test the assumption of normality, the study used the Kolmogorov-Smirnov and Shapiro-Wilks test. From this test, the Sig. (p) value was compared to the priori alpha level (level of significance for the statistic) ââ¬â and a determination was made as to reject (p à ±) the null hypothesis. The Table 1 below shows that where à ± = 0.001, given that p Table 9:à Test for Normality Test for homogeneity of variance (equality of variances). Further, to test the assumption of homogeneity of variance, where the null hypothesis assumes no difference between the two groupââ¬â¢s variances (H0: 2 ÃÆ' 1 = 2 ÃÆ' 2), a non-parametric Leveneââ¬â¢s test for equality of variances is the most commonly used statistic to verify the equality of variances in the samples (homogeneity of variance) especially for non-normally distributed data. Therefore, Kruskal Wallis one-way analysis Levenââ¬â¢s test was applied. The Leveneââ¬â¢s test uses the level of significance set a priori for the t test analysis (e.g., à ± = .05) to test the assumption of homogeneity of variance. However, in SPSS itââ¬â¢s challenging to execute Levenââ¬â¢s test for non-normally distributed data in one step. Hence steps were applied to create three new variables such as ranked data, group mean ranks and deviation from mean ranks. Finally, the differences were computed using ANOVA and the p value was found to be Table 10:à Test Statistics Mann-Whitney U and Wilcoxon W test : comparing medians. As the data is non-homogenous and non-normally distributed, Mann-Whitney U and Wilcoxon W tests were used to compare the median scores of DMFT, CPI and LOA scores, and also to check the significance of differences. Null Hypothesis: Median score of DMFT, CPI and LOA is same for both case and control. Alternative hypothesis: Median score of DMFT, CPI and LOA differs between case and control. Table 11:à Test Statistics DMFT Score CPI Score LOA Score Mann-Whitney U 403.500 340.500 374.500 Wilcoxon W 1223.500 1160.500 1194
Saturday, July 20, 2019
Comparing Themes in Catââ¬â¢s Cradle and Slaughterhouse Five Essay
Comparing Themes in Catââ¬â¢s Cradle and Slaughterhouse Fiveà à à à à à à à à à Throughout his career, Kurt Vonnegut has used writing as a tool to convey penetrating messages and ominous warnings about our society. He skillfully combines vivid imagery with a distinctly satirical and anecdotal style to explore complex issues such as religion and war. Two of his most well known, and most gripping, novels that embody this subtle talent are Cat's Cradle and Slaughterhouse-Five. Both books represent Vonnegutââ¬â¢s genius for manipulating fiction to reveal glaring, disturbing and occasionally redemptive truths about human nature. On the surface, Catââ¬â¢s Cradle and Slaughterhouse-Five are dramatically different novels, each with its own characters, symbols, and plot. However, a close examination reveals that both contain common themes and ideas. Examining and comparing the two novels and their presentation of different themes provides a unique insight into both the novels and the author ââ¬â allowing the reader to gain a fuller understanding of Vonnegutâ⠬â¢s true meaning. One of the most prevalent themes in Vonnegutââ¬â¢s works is religion. In the early pages of Catââ¬â¢s Cradle, Vonnegut submits his contention that "a useful religion can be founded on lies (Vonnegut, Cats Cradle 16)," meaning that, fundamentally, religion is about people, not about faith or God. Reminiscent of Karl Marxââ¬â¢s description of religion as the "opiate of the masses," he describes all religions as mere collections of "harmless untruths" that help people cope with their lives. The Book of Bokonon in Cat's Cradle represents this portrait of religion at both its dreariest and its most uplifting, Bokononism is contradictory, paradoxical, and founded on lies; its followers are aware of this... ...refree tone highlights them by providing irony and contrast. This unparalleled ability to seamlessly combine a light tone with serious theme is what distinguishes Kurt Vonnegut from other writers, Although Cat's Cradle and Slaughterhouse-Five share common themes, the presentation of each of the themes is different in each book. The two novels complement each othe, and comparing both can provide a higher level of understanding for each. Vonnegut never forces his opinions - he makes statements by asking questions, and presents his themes through subtle, but powerful stories, His goal is to get readers to re-examine, not necessarily to change, their lives, morals, and values. Themes such as death, war, and religion are as old as literature itself, yet Vonnegut adds a unique twist to them, inviting the reader to look at these issues from an entirely new perspective. Ã
Friday, July 19, 2019
Analysis of an Advertisement Essay -- Rhetorical Analysis
Analysis of an Advertisement Every woman wants diamonds because they are beautiful, rare, and are a symbol of success. There is something about diamonds that make every woman want one. Diamonds make a woman feel bold, sophisticated, and powerful. Something magazine recently published a diamond ad for A Diamond Is Forever.Com. A Diamond Is Forever . Com is a website that does not sell diamonds, but displays all the new styles of diamonds and how to purchase or create the perfect diamond for a customer. In this ad they are advertising a new style of diamond ring called the right hand ring. The advertisement is of a young, beautiful woman staring directly at you with a seductive look. On her right had she is wearing a bright, sparkling diamond ring that stands out. Underneath of the woman are pictures of four different styles of the diamond right ring. In the middle of the four pictures is the text ââ¬Å"YOUR LEFT HAND LOVES CANDLELIGHT. YOUR RIGHT HAND LOVES THE SPOTLIGHT. YOUR LEFT HAND DE CLARES YOUR COMMITMENT. YOUR RIGHT HAND IS A DECLARATION OF INDEPENDENCE. WOMEN OF THE WORLD RAISE YOUR RIGHT HAND.â⬠After those words are the companyââ¬â¢s slogan ââ¬Å"A Diamond Is Forever.â⬠The pictures, text, and slogan of this advertisement work together to make it one that affectively captures the audiencesââ¬â¢ attention. The purpose of an advertisement is to sell a product. Clearly, a person flipping through the pages of a magazine will be captured by the sparkling diamond and bold text. The advertisement is simple rather than one that is complex and difficult to understand. And the designer of this ad knows this. There is nothing more appealing to a woman than a sparkling diamond. The sparkling diamond catche... ...her eyes is mesmerizing. For any male, this would pull them right into the ad. Hoping to get the same look from his significant other, he would purchase a diamond for her. Also, the ad demonstrates a diamond as being a symbol of love. By talking about candlelight and commitment, romance and love is brought into perspective. The picture of this ad reminds men that diamonds are what every woman wants and that their love will last forever with a purchase of a diamond. When a reader looks at this ad, he or she is likely to be stunned by it. Its simplicity makes it easy to read and understand. Its boldness grabs your attention. And its slogan allows you to identify with its message on a personal note. Not only does the picture on the ad make diamonds look beautiful and elegant, but also the text and slogan make diamonds seem exotic and powerful.
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