Asbury University Admissions ACT Scores, Admit Rate...

The Events that Happened on December 13th - 533 Words

This research paper is about the events that happened on December 13th. I will take you through sum very interesting events that happened on this date, which is also my birthday. Personally I didn’t know that there were events like this that happened on this day. It was very interesting what I learned during this research project. I will be able to take the knowledge that I absorbed by doing this project with me through high school, college and eventually a career that fits me. My first topic is an avalanche that many soldiers died in because they were fighting for their country. This takes place in the time of WWI. This particular avalanche killed an estimate of 9,000 soldiers who were in its path. Witnesses say the avalanches were sometimes used as a weapon to kill the enemies on the mountain, soldiers that survived say the condition on the mountain was worse than the actual fighting itself. The French and Russians were against the Germans and Austrians. Most of the battle camps were set up directly under unstable snow, so whoever was in there at the time of the avalanche, they would have died. Only a few people were found out of thousands of soldiers in the battles. Another interesting event was the capturing of Saddam Hussein. Operation Red Dawn was the plan that the U.S. would try to find and execute Saddam Hussein for good He was raised into a poor family as a little child by his mother. His first wife, was his first cousin Sajida. Saddam spent many years runningShow MoreRelatedThe Legacy Of Lincoln And Andrew Johnson1017 Words   |  5 PagesI will be going through and telling you what happen through the time periods and the months. Through every time period I will tell you every event that goes on during that time period and how long is last. Basically I am giving you a research time lime from event to event. Lincoln and Andrew Johnson were out of sympathy with black suffrage, especially conferred by the federal government. Johnson s interpretations of Lincoln s policies prevailed the Congressional elections of 1866 in the NorthRead MoreBeing The Only Child - Original Writing867 Words   |  4 Pagesuntil I was about nine and as I got older the idea of ever having a younger sibling became perverse. He or she would be so annoying and instead of having fun with them, I would have to take care of them. That was something I didn’t want. Then it happened. I was twelve years old when my mom and dad sat me down with the news that I was going to be an older brother. It was October 13, 1995 when my little brother Christopher was born. He was an odd looking little thing and I wanted nothing more thanRead MoreThe End Of Chattel Slavery Essay1648 Words   |  7 Pagesfact, Classical Greece was the first society seen that had slave societies but please don’t be mistaken this was not chattel slavery. Chattel slavery in America has changed everyone’s perception on slavery itself. If the African slave trade never happened that we would be more educated on other types of slavery that existed a few centuries ago or even some thousands of years ago. In looking at my question â€Å"what was the true purpose of chattel slavery†, many researchers have argued that chattelRead MoreThe Dred Scott V. Sanford Case1670 Words   |  7 Pagesdocuments). This court ruling made useless of the Missouri compromise of 1850 which made states above the 36 °30’ line Free states and all below the line slaves states (History). This decision was eventually overturned by the Civil War amendments the 13th and 14th which stated that slavery is illegal in all states not only ones in rebellion and that all people born in the united states are citizens including people of color (our documents). To know a little background about Dred Scott, he was bornRead MoreThe Paris And Brussels Attacks1258 Words   |  6 PagesI was just a few months from my 6th birthday when the terror attacks on September 9th 2001 happened. I was too young to full grasp what was happened at the time. I knew it wasn t good by seeing everybody crying, the president was always on TV and the flags were constantly flying at half staff. Fast forwards twelve years later and now terrorist are attacking the city that I live in. Unfortunately terrorism is becoming a predominate issue for not only us in the United States but for our Allies inRead MoreRosa Parks Essay950 Words   |  4 Pagesearned by her mother, who was a teacher, and/or her father, who was a carpenter. Once she was old enough to have her own job, she went to work at the Montgomery Fair Department Store, while her husband was a barber at the time, before the boycott happened. December 5th was when a group of African-American leaders gathered to talk about tactics, and they decided that their boycott effort required a new organization and strong leadership, and McCauley ‘Parks’ was the perfect leader for it. After moving toRead MoreThe Events of Septemeber 11th, 2011: 9/11 Essay726 Words   |  3 Pageskilled during this tragic event. This major world event is referred as 9/11, which resulted in a major crackdown on terrorism. Jennifer Caverly, an 11th grade math teacher, thought 9/11 was a terrifying event †9/11 was a scary moment in my life. If someone could do that so easily, then I was terrified. I felt unsafe in this country .† She still thinks about 9/11 today. â€Å"When I think of a world event, I think about 9/11.† The attacks of September 11th, 2001, was a terrifying event that took away countlessRead MoreThe Conditions of Life for African Americans Before the 1950s773 Words   |  3 PagesCivil Rights Moment many would say that the 1950s was the catalyst for the major change that was brought upon many Americans during the African-American Civil Rights Moment. Many key events happened during the 1950s and if they creased to happen then it would be a great lose and an immense setback. Though key events did occur before the 1950s the majority were placed in the 1950s. The 1950s was a time of great importance for civil rights and essentially the spark in which great change overcame theRead MoreThe Presidential Selection Of 1860855 Words   |  4 Pageshad been at odds mostly up to that point regarding questions of states’ rights and slavery in the territories. Southerners were livid over the preparation by an abolitionist, John Brown, to establish a slave uprising at Harper Ferry, Virginia. This event garnered headlines all over the nation in newspapers and magazines. On the other hand, the Northern Republic seemed equally infuriated by the Supreme Court verdict in the case of Dred Scott v. Stanford, which affirmed free soil unconstitutional. TheRe ad MoreThe Presidential Election Of 1860848 Words   |  4 Pagesnation had been divided mostly up to that point regarding questions of states’ rights and slavery in the territories. Southerners were outraged over the plan by abolitionist, John Brown, to start a slave rebellion at Harper Ferry, Virginia. This event garnered headlines all over the nation in newspapers and magazines. On the other hand, the Northern Republic seemed equally anger by the Supreme Court decision in the case of Dred Scott v. Stanford, which declared free soil unconstitutional. The

Basic Solutions for Bad Study Habit Free Essays

†¢Balancing school and friends. This can be a challenge. Friendships are important but so is school. We will write a custom essay sample on Basic Solutions for Bad Study Habit or any similar topic only for you Order Now The best way to balance school and friends is to study together. Good friends will support your academic and future goals. You can also make friends with other people who are planning for college and taking the same classes as you. †¢Add interest to your reading assignments. To get through a long reading assignment, imagine yourself in the story. Get involved. Ask yourself, â€Å"What is important to remember about this section? † You should always take notes or underline key sections and discuss the material with others in your class. You can also create a study group and break the assignment into different sections. Each person can be responsible for closely studying one part of the text. The other parts you can skim or outline. Then get together as a group to share what you’ve learned. †¢Cramming before a test. Cramming before a test is always a bad idea. Start studying well in advance. Begin with an hour or two a day and then increase your study time as exams approach. †¢Don’t know where to start. Your challenge is to prioritize. With a big project, list all the things you have to do. Then split the project into small, manageable chunks. Ask, â€Å"Which part is due first? Which part of the assignment is worth more points? Which task will take the most time to complete? † Decide which tasks are most important and what order you’ll use to get things done. Then get started! The most important thing to remember is start early and work a little bit each day. You’ll be amazed at how much progress you make. †¢Staying up all night to study. Before a test, it is important to get enough sleep. Period. Make time to relax and unwind before each test. Be sure to eat well, sleep well and maybe get some exercise. You’re more likely to do better on the test if you take care of yourself. †¢Not enough time to study. The trick to solving this problem is getting organized. Bring out all of your notes and textbooks. Identify the most important information and the things you don’t understand. Focus your study time and energy on learning those things. If you need extra help, ask a teacher or tutor. If after school activities are the problem, keep a calendar with game days, meetings, assignments and practice times. Start assignments right when you get them, and use lunch hours and breaks to make extra progress. †¢Trouble remembering things. If you only have trouble sometimes, try connecting new information with your own examples and experiences. Use rhymes, poems or mental pictures to help remember important facts. Some people even make up songs to help them remember things. If you always have trouble remembering, no matter how long or hard you study, talk to your teacher or school counselor. They can talk with you about your specific problems and recommend strategies to help. How to cite Basic Solutions for Bad Study Habit, Essay examples

Global consumerism Essay Example For Students

Global consumerism Essay Kleenex, Band-Aid and Coke all marketed their brands too well over the years. To many, every tissue is a Kleenex, and every small plastic or fabric bandage is a Band-Aid. On the other hand, people may refer to all (or perhaps only the dark) soft drinks as Cokes, but that company enjoys a high level of customer loyalty that other common brands do not. Building the Brand The opposite side of well-known brands is that consumers readily differentiate product classes between brands. Ketchup is not referred to as a generic Heinz as is the case with tissues and bandages, yet consumers make clear distinction between Heinz and other brands of ketchup. They also have their favorites and generally will not stray from the one to which they have assigned their loyalties. Coca-Cola has the worlds most recognizable brand and is available all around the world. The entire beverage industry has undergone changes in recent years that have affected Coke along with its competitors. Nearly from its inception, the mission of the Coca-Cola Company has been to make the product a universal, global one. One sees them everyday. Pictures of cars, images of gleaming coffeepots, and dancing soap bubbles. Ask any adult in their late twenties to sing a jingle from McDonalds, and the version given will more than likely include Hold the pickles, hold the lettuce, special orders dont upset us. Why after all these years has the jingle become part of the collective consciousness? Because thats the power of advertising. Advertising has been synonymous with the human experience since very early times. This has been shown to be true as excavations in Pompeii and early Rome show advertisements for property rental and goods(Wissen Erleben 2002). In America, advertising began around the early 1870s and included a new idea: mail order catalogues. These were developed in response to the location of most of the consumer base. They were very rural and families did not live near one another. This helped to solve the situation, and since then catalogue sales have been a cultural fact, and a form of advertising that has gone global. .

The One Thing Needful from the Hard Times by Charles Dickens Hard times, published in 1854 Essay Example For Students

The One Thing Needful from the Hard Times by Charles Dickens Hard times, published in 1854 Essay The One Thing Needful from the Hard Times by Charles Dickens Hard times, published in 1854, Dickens shortest novel was not popular in its day, though it has since received critical acclaim for its rousing satire against materialism. This is quote taken from Msn Encarta Encyclopedia. This extract is about a person who is considered to have authority and to be greatly respected telling other grown-ups how he wants children to be taught and how they should be taught, this shows what education in the 19th century might have been like. The main purpose of this text is to emphasise what should be taught and how it should be taught and the speaker thinks that by enforcing a teaching method, children will have better lives as it would be based on nothing but facts. This passage makes modern children compare and think about how lucky they are to be able to express how they feel and imagine things. The way the word Facts is written and repeated shows their importance in the speakers life, this also highlights how important the thought of teaching facts is, well at least to the speaker, this explains why it is written as a proper noun with the use of a capital letter, the speaker personifies Facts. Dickens deliberately uses repetition to represent the way in which children learn, by repetition. The speaker refers to children in several ways, but his main point is that children learn by things being repeated to them. We will write a custom essay on The One Thing Needful from the Hard Times by Charles Dickens Hard times, published in 1854 specifically for you for only $16.38 $13.9/page Order now This explains why he calls them reasoning animals, because animals learn by things being repeated to them and once they are used to it they would do it automatically. The speaker is trying to say that teaching them facts is like training them to be good, but unlike animals, human beings especially children have opinions and wild imaginations. Dickens uses a metaphor, which could have different meanings. Plant nothing else and root out everything else. The fact he uses gardening shows that children are just like a garden: they have a lot of things in their heads, but grown-ups have to plant the seeds which are the facts in the garden to be able to make them grow properly. The structure of the passage has a great impact on what the reader thinks about the speaker after having read the first paragraph and after having read the last paragraph. From the way in which the writer describes the speaker, the audience has a clear understanding that the writer does not like the speaker. He is not mentioned by any names or titles but as the speaker; this leaves the reader to guess his identity and distances himself from the speakers view. The description of the speaker matches his sentence structures in the quotes. They are short, snappy and straightforward. Dickens describes him as square to show that he is predictable and unchangeable. The speaker makes sure that his point gets across and to do so he uses a harsh, strict tone. Dickens uses hyperbole to describe the speaker by describing him using a great deal of exaggeration square wall of forehead line 10, his eyes found commodious cellarage in two dark caves, overshadowed by the wall. Line 12, a plantation of firsline 16, square coat, square legs, square shouldersline 19. This is shown by the repetition of the word square and makes the reader be perceived as the best. Victorian education was Dickens main focus in most of his novels. He uses different social classes to make the audience especially young people see that education should not be taken for granted and that if they think their teaching system is harsh, they should look at what it used to be like in Victorian times. The language used is not hard however everything is straightforward and easy to understand as well as imagine. Twelfth Night by William Shakespeare Act 1 scene 1. This scene is a strange opening for a play. Orsino says how much he loves Olivia, but he is told that she is still mourning her brothers death for seven years. .ub73a9dba5831c92f001e7c41259b479d , .ub73a9dba5831c92f001e7c41259b479d .postImageUrl , .ub73a9dba5831c92f001e7c41259b479d .centered-text-area { min-height: 80px; position: relative; } .ub73a9dba5831c92f001e7c41259b479d , .ub73a9dba5831c92f001e7c41259b479d:hover , .ub73a9dba5831c92f001e7c41259b479d:visited , .ub73a9dba5831c92f001e7c41259b479d:active { border:0!important; } .ub73a9dba5831c92f001e7c41259b479d .clearfix:after { content: ""; display: table; clear: both; } .ub73a9dba5831c92f001e7c41259b479d { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ub73a9dba5831c92f001e7c41259b479d:active , .ub73a9dba5831c92f001e7c41259b479d:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ub73a9dba5831c92f001e7c41259b479d .centered-text-area { width: 100%; position: relative ; } .ub73a9dba5831c92f001e7c41259b479d .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ub73a9dba5831c92f001e7c41259b479d .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ub73a9dba5831c92f001e7c41259b479d .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ub73a9dba5831c92f001e7c41259b479d:hover .ctaButton { background-color: #34495E!important; } .ub73a9dba5831c92f001e7c41259b479d .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ub73a9dba5831c92f001e7c41259b479d .ub73a9dba5831c92f001e7c41259b479d-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ub73a9dba5831c92f001e7c41259b479d:after { content: ""; display: block; clear: both; } READ: JD Salinger s Catcher in the Rye Compared to Mark Twains EssayOrsino loves her so much that he imagines her being in love with him and compares two different kinds of love: the love she has for her brother and the love that she might have for him one day. The purpose of this text is to engage the reader into the theme of the play and most of the times when something is about love, there is a show of great interest. Shakespeare used a great method by opening with play with rhymes that is guaranteed to catch the readers attention. This scene shows the impact love has on people. It makes it interesting that the play opens directly telling the reader what is happening. There is no background information, the only piece of information that the reader gets from this extract is that Orsino is the Duke of Illyria and is deeply in love; he sounds a little bit obsessed with the idea of love and this extract allows the reader to see what kind of personality Orsino has. He can be portrayed as someone highly emotional and someone who will fight to get what he wants. The language used in this text is quite hard to understand if you are a young person who is not used to hearing the traditional way of the English language. Some words are quite easy to understand, as they are quite similar to the words we use nowadays, or we can relate them somehow. Pestilenceline 20 means plague but this could be guessed with pestilence. This play uses imagery containing food. Orsino describes his love for Olivia as an appetite: If music be the food of love play on, Give me excess of it- that, surfeiting, The appetite may sicken, and so die line 1-3, he wants to feed his love with music, he wants to feed it so much that he would be full and become sick of it and wont feel his love anymore. This is also used when Olivias grief is described. In this case water is used to describe Olivias mourning. Shakespeare uses different parts of the body to show the same emotion- love hart eyes liver brain lines 18 and 27. He constantly uses the sense of smell and taste, The sweet sound That breathes upon a bank of violets line 6, stealing and giving odour line 7, tis not sweet nowà ¢Ã¢â€š ¬Ã‚ ¦ Line 8 Sweet beds of flower line 40. This may induce some sexual thoughts into the readers mind. The language used makes the reader feel what the characters are feeling especially if they have felt like that about someone before. The fact that Orsino goes into great detail about his love for Olivia shows the reader that he is willing to do anything to win her heart. The use of abstract nouns, love and grief makes the reader feel pity for the characters. There is a simile That, notwithstanding thy capacity, Receiveth as the sea line 10-11 which suggests that love is like the sea, devouring everything. Nothing can satisfy it. Shakespeare also uses hyperbole to show the love that Orsino has for Olivia and the grief Olivia has for her brother. I dont think there is a historical context in Twelfth Night; it seems to be purely fictional. However this was set in the Elizabethan era. Since Shakespeare wrote Twelfth Night a lot has changed and mainly peoples sense of humour, even though this play was a comedy in Shakespearean times it may not be what we call a comedy now. During that time women had a poor role in society, there was this idea of the women not being allowed to do certain things such as, acting therefore, men had to play the role of women and unlike all his other comedies, twelfth night includes a conception of love and other themes which most of his other comedies do not have, this was one of his last three mature comedies. .u3d1be5985a49df8d1e19315f851639e0 , .u3d1be5985a49df8d1e19315f851639e0 .postImageUrl , .u3d1be5985a49df8d1e19315f851639e0 .centered-text-area { min-height: 80px; position: relative; } .u3d1be5985a49df8d1e19315f851639e0 , .u3d1be5985a49df8d1e19315f851639e0:hover , .u3d1be5985a49df8d1e19315f851639e0:visited , .u3d1be5985a49df8d1e19315f851639e0:active { border:0!important; } .u3d1be5985a49df8d1e19315f851639e0 .clearfix:after { content: ""; display: table; clear: both; } .u3d1be5985a49df8d1e19315f851639e0 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u3d1be5985a49df8d1e19315f851639e0:active , .u3d1be5985a49df8d1e19315f851639e0:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u3d1be5985a49df8d1e19315f851639e0 .centered-text-area { width: 100%; position: relative ; } .u3d1be5985a49df8d1e19315f851639e0 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u3d1be5985a49df8d1e19315f851639e0 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u3d1be5985a49df8d1e19315f851639e0 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u3d1be5985a49df8d1e19315f851639e0:hover .ctaButton { background-color: #34495E!important; } .u3d1be5985a49df8d1e19315f851639e0 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u3d1be5985a49df8d1e19315f851639e0 .u3d1be5985a49df8d1e19315f851639e0-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u3d1be5985a49df8d1e19315f851639e0:after { content: ""; display: block; clear: both; } READ: Frankenstein by Mary Shelley and Benito Cereno by Herman Melville EssayTwelfth Night is a celebration of romantic love that can be pictured as traditional romantic love. The play contains many elements of Elizabethan romantic comedy. The things that are in the play are meant to make the audience go through a series of moods. Because this play is a comedy most of the things that happen are meant to make the audience laugh. It does achieve this aim with nearly every character. However in the opening scene, the main emotions that Shakespeare wants the audience to feel are pity and grief. Samaritans This text is about ways to identify people who want to commit suicide and how to help them. The purpose of this text is to make the readers aware of things that are happening in their surroundings. This makes the reader think and may prevent many people from committing suicide and to advertise them of what to do. This text is written in interrogative form because this makes the reader wonder and understand the reasons why people would try to commit suicide. I would associate this extract with mostly teenagers, as they are the ones who undergo the situations listed however this can happen to anyone, but mostly teenager would want to commit suicide if they are dumped by their loved ones. The first paragraph is written as a question but due to the punctuation it could be classed as a declarative sentence. The first sentence after the first paragraph is a statement, which is followed by a question and then an answer, which doesnt directly answer the question. Unlike all the other extracts this extract is not fiction therefore it focuses on a more serious issue. The use of bullet points attracts the reader to indulge into the extract and might make some readers want to know more about suicide. This could also restrict those who are trying to commit suicide to what they will tell people. Even though this subject is quite delicate, there is no use of euphemisms or dysphemisms. Everything is straight to the point; nothing is exaggerated or left out. There a lot question which are facts that people need to consider in order to look out for themselves and others. The way the questions are posed will make the reader observe the people around them and try to help them if they see any of the suicidal signs. There are 1745 words in this document AUTHOR Fatim Toure Page PAGE 4 DATE 20/02/2006 Reading and comprehension of texts

Deluxe Corporation Case Essays

Deluxe Corporation Case Essays Deluxe Corporation Case Paper Deluxe Corporation Case Paper By: Michael Malone Statement of the Problem Rajat Singh, a managing director at Hudson Bancorp, needs to find a way to rejuvenate the paper check corporation. One main part that needs to be calculated is the appropriate mixture of debt and equity for the firm. The company needs to determine the correct mixture so that they can both minimize the cost of capital and increase the shareholders value. I will analyze the current and future situation of the company, trying to find the correct credit rating to use that will increase income. With the new credit rating, I will be able to recommend a certain amount of debt for the company to take on and be profitable. Facts and Assumptions When trying to accurately calculate the cost of capital, the one main method stands out the most. I had to calculate the WACC of the firm for the various credit ratings. In order to accurately calculate this, I had to incorporate the repurchase of shares and add the newfound debt to the total debt from 2001. The project debt used by the corporation didn’t factor in the repurchase of shares and therefore it was calculated wrong. To help me solve the equation for the best WACC, I had to make some basic assumptions about the case. For starters, as shown in case, I decided to use a 37% tax rate like the analysts for Bancorp did because I felt that it would be comparable to the numbers that they calculated in the projection. Next, I decided to use the 5-year note yield because analysts provided information to show that the market would mature after 5 years and paper checks would be nonexistent. Furthermore, I had to use the CAPM equation to figure out what my numbers would be for the WACC equation. To show this, I used the equation: CAPM = Rf + (Rm-Rf) ? Through the use of the case, I was able to assume a risk free rate of 3. 45% while I used 11. 03% for the market risk premium and 0. 85 and the beta. This led us to the calculation of the cost of equity, which we could then use to find the debt. Once the debt was found, I needed to find the bond rating perfect or it and I believe that I found a winner. Analysis Using CAPM to provide the calculation for the equity, this presents both positive and negative effects. Advantages 1. Calculates the amount of compensation the investor demands for taking additional risk 2. Compares the returns of the asset to the market over a period of time (Beta) Disadvantages 1. Based on historical data onto the future (Beta is an estimate) 2. Simplifies assumptions about the market and how investors will actually behave. Taking the CAPM equation, we were able to figure out eh cost of equity and in its credit range CAPM = Rf + (Rm-Rf) ? =3. 45%+(11. 03%3. 45%)*0. 85 CAPM= 9. 89% With this, we can then find each of the costs for equity by averaging them within each of the bond rating categories. This showed a very flat performance in cost of equity. I we compare that to the market beta, our answer for CAPM would change from the 9. 89% to the 11. 03%. According to exhibit 8 in the case, a cost of equity of 11. 03% is between a BBB and BB bond rating. Therefore, if they were to repurchase stock from investors, there share prices would in theory go up because they are investing more and more money into the company. With the three debt instruments in the case, hundreds of millions of dollars would become readily available to the company and be at their disposal. Each of the financing opportunities provides their own money in different forms. Great companies need these different financing ideas to succeed. Recommendation Based on the analysis performed, Deluxe should definitely consider the different financing opportunities that are presented to them. By epurchasing stocks with debt, the stock price will increase from $41. 58 to $47. 04. This will bring some much needed value to both the company and its investors. In my opinion, the company shows a good potential to continue to grow during the recession through he addition of new financing opportunities and buyback of some stock. To get this to happen, it would require the company to use 1,140. 10 million dollars of debt which would equate to a mixture of 64. 85% debt and 35. 15% equity.

Film analysis 2 Essay Example | Topics and Well Written Essays - 750 words

Film analysis 2 - Essay Example The gifted jazz musicians try to put together their band. They search for their big hit while their lives are entangled in one night stands and flickering love affairs. The narrative or the genre is uncanny because it is a collection of different genres. It is a musical due to so many musical numbers in the movie. It is also a drama for the characters represent different traits. There is a character played by Jack Carson which is the manic-depressive bandleader, while Elia Kazan plays the free-spirited clarinetist. The movie also incorporates the film noir genre which is probably its highlight. An escaped convict joins the band and starts his affair with the femme fatale, played by Bettie Field. This unholy union proves to be the cause of the band’s destruction. Hence the narrative structure is a collage of different film genres. Storytelling and narrative are similar in the sense that the story incorporates so many genres that it is difficult to establish a conventional ‘storytelling formula’. There are many twists and turns that movie is hardly predictable. It also makes audience confused which is evident by mixed reviews about the movie (Othman, 1941). The way the band gets together is strange but very interesting. Somehow the band members get locked up in the same cell at a police station where they hear a blues singer singing. It is a perfect beginning for the movie as it serves as the hook of the whole plot. The audiences start thinking about this new form band and think whether it will do good or will become oblivion. The New Jersey roadhouse called The Jungle becomes their first performance stage. The way screenwriters connect the bad with this roadhouse is through a character named Del. the meeting between the two is so strange that the character first robs them and then shows them the way to the roadhouse. After watching the movie the audiences might feel a little

Ethical Behavior and Ethical Lenses Of Baird Essay

Ethical Behavior and Ethical Lenses Of Baird - Essay Example The ELI is sure to facilitate the self-discovery of one’s underlying values which help individuals to identify their preferred approach to solving ethical dilemmas. One’s personal code of ethics is shaped by one’s family members, teachers, norms and regulations of the community, formal and informal education, philosophy, morality and religion. Similarly, each profession and organization has its own ethical codes (values, expectations and set of preferences) which the employees have to follow. It is also important for individuals to identify the values in conflict through greater self-knowledge. These values in conflict are the result of differences between one’s personal and community values, conflicts as to which personal value should take priority in a given situation, and the disparity between one’s best and worst selves. The ELI will also equip one to identify one’s values in conflict and as such this paper seeks to address my personal et hics statement based on Baird’s ethical decision model. For Baird, the four basic values that form one’s ethical behavior and determine one’s primary ethical lens are rationality, sensibility, autonomy and equality. Among these, rationality stresses on reason, principles, critical thinking and analysis; sensibility emphasizes empathy and compassion where the individual follows his heart or intuition in ethical decisions; autonomy favors personal rights and responsibilities in ethical behavior whereas equality takes into account the needs of the community in ethical choices (Baird & Niacaris 11). Analyzing my own ethical values it is evident that rationality stands at the core of my ethical statement. I strongly believe in the power of reason, principles, critical thinking and analysis in making ethical choices. However, regarding the priority of values to be undertaken in various situations I stand divided between autonomy and equality. Even though I am a strong advocate of equality and value the needs of the community I favor my personal rights and responsibilities as well in many instances. Therefore, I realize that there are certain conflicts of values with regard to my ethical decisions which I need to sort out carefully. It is also worthwhile to analyze the four ethical lenses of Baird to have a thorough understanding regarding my own ethical perspectives. For Baird, one’s value preferences determine one’s ethical lens and therefore it is significant to identify my own core values and the corresponding ethical lens. Baird categorizes the ethical lenses into four: rights and responsibility lens, results lens, relationship lens, and reputation lens. The Rights and Responsibility Lens emphasizes the core values of autonomy and rationality and it holds that the individual is capable of making his own ethical choices through critical thinking and analysis. On the other hand, the Results Lens emphasizes the core values of auto nomy and sensibility and the focus of the individual is on the results or consequences of his actions. As such the ethical perspective has its roots in the teleological tradition which stresses on utilitarianism. The third ethical perspective is the Relationship Lens that emphasizes the core values of equality and rationality, traditionally known as theories of justice and it has its roots in the deontological tradition. This ethical perspective exhorts one to treat everyone in the community with respect and dignity. On the other hand, the Reputation Lens emphasizes the values of equality and sensibility and the lens focuses on what virtues the community believes should be cultivated by those in positions of responsibility. With regard to my e

Methods to measure gene expression in mammalian cells in vitro and in Essay

Methods to measure gene expression in mammalian cells in vitro and in vivo - Essay Example This method is based on suppression PCR technique that is a combination of normalization and subtraction in one procedure. The normalisation technique would equalize cDNA abundance in the target population while the subtraction step excludes the sequences that are common between the target and driver populations. 5 The two type of real – time PCR are the molecular beacon and SYBR Â ® Green method. SYBR Â ® Green method is the first method that was used in real – time PCR wherein it binds to double – stranded and when this would get excited, would emit light. On the other hand, molecular beacon utilizes a reporter probe that is wrapped to the hairpin.9 Involves mRNA isolation and hybridisation. mRNA is extracted and purified from the cells. To proceed with electrophoresis, mRNA is loaded to the gel. The current is allowed to pass through the gel and mRNA will move away from the negative electrode. To visualize mRNA, Flourescent dye is used as a stain followed by UV lighting. RNA is then transferred to a membrane from the gel electrically or through capillary action using a high – salt solution. RNA fragment that is in question is incubated with the blot and to remove the probe, the blot is then washed. Developmental step follows.10 A method to analyse comprehensively patterns of gene expression.8 mRNA is isolated from the sample. A small chunk of sequence is then extracted and these small pieces are sequenced together forming a long chain. These chains are cloned into a vector that can be taken up by bacteria. These chains are sequenced using a modern high. The data is then processed with computer in order to count small tags sequence.13 This method works at the 3 terminal portions of mRNAs by systemic amplification and resolution on DNA sequencing gel fragments. Primers are anchored and are designed to bind to 5 boundary of the poly-A tails for the reverse transcription.

Impact of Curriculum Definitions and Theories

Impact of Curriculum Definitions and Theories This essay will examine several definitions of curriculum, relating one to Education and Childhood studies and the impact it has on learners. In addition, the essay sets out to explore curriculum in relation to delivery and Curriculum is often seen as the main concern in the educational field however, the type of curricula to offer to learners is crucial. The concept of curriculum is sometimes characterized as fragmentary, elusive and confusing. Teachers are concerned about the choices to make about the teaching content and methods of delivery. While, caregivers and parents are interested in knowing what is going to be taught to their children. Learners are equally concerned about the content they are going to receive in class. The concept of curriculum is as dynamic as the changes that occur in society. In its narrow sense, curriculum is viewed merely as a listing of subject to be taught in school. In a broader sense, it refers to the total learning experiences of individuals not only in schools but in society as well. Su, (2012) views Curriculum as what teachers will teach and how well learners will learn, it also involves other issues like:ÂÂ   teaching the curriculum, testing the curriculum, ad ministrative curriculum and the hidden curriculum. However, Kelly (1999, p.83), suggest that curriculum is negatively viewed as a syllabus which may limit the planning of teachers to a consideration of the content or the body of knowledge they wish to transmit or a list of the subjects to be taught or both. However, (Braslavsky, 2003) considers the curriculum as educational foundations and contents, their sequencing in relation to the amount of time available for the learning experiences, the characteristics of the teaching institutions, the characteristics of the learning experiences, from the point of view of methods to be used, the resources for learning and teaching (e.g. textbooks and new technologies), evaluation and teachers profiles. A curriculum is an intended programme of learning and has three elements: a set of curriculum standards which set out the expected student achievements (what they know, what they can do and what dispositions they have acquired) at set points of time, the student having taken part in a programme of learning; a set of pedagogical standards; and a set of summative assessment or evaluation standards (Scott,2016 p.4). Having explored some definitions of curriculum, Scotts definition best fits the curriculum delivered on the Education and Childhood Studies programme. The curriculum covers several courses that ensures learners have an informed knowledge of the course to prepare them for the next step in their career. The curriculum covers a range of courses indicate; The curriculum has an intended programme of learning which learners are expected to complete at the end of the course. For each of the modules, the learning outcome is clearly outline which guides teachers to effectively plan and deliver contents to ensure learners makes progress, paying attention to teaching and learning strategies which will facilitate learners engagement and participation. Progress is usually monitored throughout lessons in form of formative assessment ensuring learners know what they do and what dispositions they have acquired. Furthermore, at the end of each module a set of summative assessment are used to evaluate learners achievement and progress. The curriculum delivered in the Skills Company on the Access for Higher Education, is a tailored towards the learner gaining a qualification towards a place to study in a university of the learners choice provided learners achieve the required grades. Ornstein and Hunkins (2009, p.15) contend that curriculum development encompasses how a curriculum is planned, implemented and evaluated, as well as what people, processes and procedures are involved When the phase in life is reached where education begins in earnest, it is vital that the curriculum is integrated, that there is no separation of theory and practice. By this Plato seems to mean that learning the theory of something is by itself of little value unless the student knows how to make it work.

Puritans and Puritanism Essay -- American History

Puritans and Puritanism This essay addresses the questions: What is Puritanism. What is the meaning of puritanism in American history? What is the Covenant as Puritans understood it. How were their ideas about the Covenant applied to their experience in America? Puritanism is one of the most important aspects of the American culture. Many of this country’s beliefs come from puritanism background. What is Puritanism and the meaning of it in American history? Puritanism is a term that originates from the religious group called the Puritans. They were a denomination formed by the great Protestant Reformation in Europe. They were known as nonconformists and dissenters because of their refusal to submit to the Church of England. Because of this, the Puritans and their theology soon died out in Europe. However, the puritan ideas and beliefs flourished in the New World. Puritanism starts with the theology of the Puritans. First they believed in the sovereignty of God. That is, only God had the highest power or rank. This meant that a man did not have the power to hold authority over other men. In essence, this belief coincides with the concept of the divine nature of kings. The English monarchy wanted its people to believe that the king was appointed by God Himself. Therefore, the king was responsible only to God. The first concept of Puritanism states that all Christian men are responsible only to God. Another concept of puritanism and probably the most important is the idea of Salvation by Grace. In Puritan theology, God created mankind and cosmos. He gave mankind a beautiful garden to live, the Garden of Eden. Unfortunately, mankind committed sin and was banished. However God, sent His grace to mankind. He gave His... ... was to give African slaves their freedom. Then, there was the westward movement to expand land. During the 20th century, the United States fought to protect the world from the Axis, the Communists, and the Iraqis. In each case, America has always had this special mission which they fulfilled sometimes using questionable methods. We can see how puritanism relates to the beliefs of America by studying the history of America. And we can see the prominent role puritanism has played to American society. Just look at the remnants of the Indian culture. Using the name of God, the Americans stole their land, wiped out their people, and destroyed their culture. Perhaps the sovereignty of God isn’t such a good idea after all. It seems as though with no authority to answer to except God, America was able to do almost anything and state that it was for the â€Å"greater good.†

Book of mormons review

We entered the Prince of Wales Theatre in the Westminster area of London on a beautiful evening on the 27th of April. The show was sold out but the lines were Incredibly manageable. There was a bit of electricity In the air. I tried to gauge what it was but couldn't put my finger on It. Was it Just anticipation? Maybe it was the beautiful weather that made people lively. After grabbing a quick cocktail to get ready for the show, the signal came to take your seat. The show was ready to start! The show began. From the very beginning, it was obvious that the producer's were going to pull out all of the comedic stops.The bludgeoning of the Mormon faith began in earnest and you got a quick feeling that there could be some cringing moments In the play. I found myself looking around at the audience during the first act to see what was happening on people's faces. I saw shock and awe. I saw older women in their seventies laughing to the core at some of the more raunchy material. Some of the audience members appeared conflicted in how they should respond. Here was a play making direct attacks on a large religion and mixing In sex, nasty language and blasphemy to entertain the audience.Is it k to laugh? Evidently, most people felt like it was perfectly fine because the first part of the play was non-stop laughter, great music and fabulous acting. Every character had his/her own personality and grew Into their roles, I felt Like the first part of the play was over before in no time. The second half of the play picked up where the first half left fifth surprise and honeybees. There was a small period at the beginning of the second part where the play did slow down a little bit. The scene was a little slow and the music was not as lively as other music pieces.It did pick back up and the second part of the play need with several twists that were unexpected and that really brought all of the themes of the play back together for what was a fantastic ending. The Prince of Wales Theatre was a beautiful venue with the expected perks of a venue named after royalty. The sound was of the highest quality. The seats were The producers decided on a very simple set. While there were a few special effects, the majority of the play was staged on Just a few sets that were role on and off the stage by the actors. No incredible electronics to manage set logistics.Just old- fashioned stage set changing. The lighting was satisfactory. There was not a lot of opportunity to mix the lighting effects up. Now to the performers. The primary characters were the Elders who were part of the Mormon mission. The main character, Elder Price played by Gavin Creel, performed well throughout most of the show but seemed to fizzle a bit toward the end. Elder Cunningham, played by Jarred Greener, seemed to be an odd choice for the role but really developed the character throughout the play and sold most of the audience by the time the show ended. The lead Elder, Elder McKinley was played by Stephen Sheffield.He was steady and consistent throughout and really added some surprising comic relief. While I wont go through all of the characters, the tribal characters all had unique roles and managed them to perfection. I have to say that I walked away from the play with an embedded grin on my face. I was totally shocked by the extreme sarcasm displayed and the total dismantling of a faith and its beliefs. I walked away scratching my head at the Mormon faith, its origins and its validity. That is quite an accomplishment! I would highly recommend everyone to see the play and to enjoy an evening of fun and laughter.

Career Options for Archaeology Degrees

Career Options for Archaeology Degrees What are my career choices in archaeology? There are several levels of being an archaeologist, and where you are at in your career is related to the level of education you have and the experience you’ve received. There are two common types of archaeologists: those based at universities, and those based at cultural resource management (CRM) firms, firms that conduct archaeological investigations associated with federal construction projects. Other archaeology-related jobs are found at National Parks, Museums, and State Historical Societies. Field Technician/Crew Chief/Field Supervisor A field technician is the first paid level of field experience anyone gets in archaeology. As a field tech, you travel the world as a freelancer, excavating or conducting survey anywhere the jobs are. Like most other kinds of freelancers, you are generally on your own when it comes to health benefits, but there are benefits to the ‘travel the world on your own’ lifestyle. You can find work on CRM projects or academic projects, but in general CRM jobs are paid positions, while the academic field jobs are sometimes volunteer positions or even require tuition. A Crew Chief and Field Supervisor are Field Technicians who have had enough experience to earn additional responsibilities and better pay. You’ll need at least a Bachelors level (BA, BS) college degree in archaeology or anthropology (or be working on one) to get this job, and unpaid experience from at least one field school. Project Archaeologist/Manager A project archaeologist is the middle level of the  cultural resource manager jobs, who supervises excavations, and writes reports on excavations conducted. These are permanent jobs, and health benefits and 401K plans are common. You can work on CRM projects or academic projects, and under normal circumstances, both are paid positions. A CRM Office Manager supervises several PA/PI positions. You’ll need a Masters Degree (MA/MS) in archaeology or anthropology to get one of these jobs, and a couple of years experience as a field technician is very helpful, to be able to do the job. Principal Investigator A Principal Investigator is a Project Archaeologist with additional responsibilities. She conducts archaeological research for a cultural resource management company, writes proposals, prepares budgets, schedules projects, hires the crew, supervises archaeological survey and excavations, supervises laboratory processing and analysis and prepares as sole or co-author technical reports. PIs are typically full-time, permanent positions with benefits and some retirement plan. However, in special cases, a PI will be hired for a specific project lasting between a few months to several years. An advanced degree in anthropology or archaeology is required (MA/Ph.D.), as well as supervisory experience at the Field Supervisor level is also required for first time PIs. Academic Archaeologist The academic archaeologist or college professor is probably more familiar to most people. This person teaches classes on various archaeology, anthropology or ancient history topics at a university or college through the school year, and conducts archaeological expeditions during the summer terms. Typically a tenured faculty member teaches between two and five courses a semester to college students, mentor a select number of undergraduates/graduate students, run field schools, conduct archaeological fieldwork during the summers. Academic archaeologists can be found in Anthropology Departments, Art History Departments, Ancient History Departments, and Religious Studies Departments. But these are relatively difficult to get because there arent that many universities with more than one archaeologist on staff- there are very few Archaeology Departments outside of the larger Canadian universities. There are Adjunct positions easier to get, but they pay less and are often temporary. You’ll need a Ph.D. to get an academic job. SHPO Archaeologist A State Historical Preservation Officer (or SHPO Archaeologist) identifies, evaluates, registers, interprets and protects historic properties, from significant buildings to shipwrecked vessels. The SHPO provides communities and preservation organizations with a variety of services, training and funding opportunities. It also reviews nominations to the National Register of Historic Places and oversees the State Register of Historic Sites. Has a very large role to play in a given states public archaeology effort, and is often in political hot water. These jobs are permanent and full-time. The SHPO, him/herself, is usually an appointed position and may not be in cultural resources at all; however, most SHPO offices hire archaeologists or architectural historians to assist in the review process. Cultural Resource Lawyer A cultural resource lawyer is a specially-trained attorney who is self-employed or working for a law firm. The lawyer works with private clients such as developers, corporations, government, and individuals in connection with a variety of cultural resource-related issues that may arise. Those issues include regulations that must be followed in connection with property  development projects, ownership of cultural property, treatment of cemeteries located on the private or government-acquired property, etc. A cultural resource attorney may also be employed by a government agency to oversee all cultural resource issues that may arise, but will probably entail work in other environmental and land development areas as well. She may also be employed by a university or law school to teach subjects related to the law and cultural resources. A JD from an accredited law school is required. An undergraduate degree in Anthropology, Archaeology, Environmental Science or History is helpful, and its beneficial to take law school courses in administrative law, environmental law and litigation, real estate law and land use planning. Lab Director A laboratory director is typically a full-time position at a large CRM firm or university, with full benefits. The director is in charge of maintaining artifact collections and the analysis and processing of new artifacts as they come in out of the field. Typically, this job is filled by an archaeologist who has additional training as a museum curator. Youll need an MA in Archaeology or Museum Studies. Research Librarian Most large CRM firms have libraries- both to keep their an archive of their own reports on file, and to keep a research collection. Research librarians are typically librarians with a degree in library science: experience with archaeology is typically beneficial, but not necessary. GIS Specialist GIS Specialists (Geographic Information Systems (GIS) Analysts, GIS Technicians) are people who process spatial data for an archaeological site or sites. They need to use software to produce maps and digitize data from geographic information services in universities or large cultural resource management companies. These can be part-time temporary jobs to permanent full time, sometimes benefited. Since the 1990s, the growth of Geographic Information Systems as a career; and archaeology has not been slow in including GIS as a sub-discipline. Youll need a BA, plus specialized training; archaeology background helpful but not necessary.

Billy Budd by Herman Melville Essay Example

Billy Budd by Herman Melville Essay Example Billy Budd by Herman Melville Paper Billy Budd by Herman Melville Paper The story, Billy Budd, by Herman Melville embodies many themes.   The same story has also been the subject of many different interpretations because of these themes.   One of the more popular interpretations has to do with the many different allusions to the holy Christian bible.   Billy has often been interpreted as Adam from the book of Genesis, while his counterpart, Claggart, has often been compared to the serpent in the Garden of Eden or as Satan.   The reason for this comparison has to do with the sacrifice that Billy makes at the end of the story.   Good natured and kind hearted, Billy becomes the innocent victim of a harsh society.   In order to make this portrayal, however, it is necessary to briefly discuss the trials and tribulations that Billy endured. The goodness of Billy is highlighted more during the times when Claggart tries to tempt Billy in committing dastardly acts and deeds of evil; the temptations that Claggart dangles in Billy’s way show Claggart’s different attempts to destroy the character of Billy.   This is analogous to the situation in the Garden of Eden where the Serpent tries to deceive Adam into taking the fruit of the forbidden tree.   The description of Claggart’s dead body as it lies lifeless in the form of a snake reinforces this point. This is an important characterization that is used well in the story as it makes it easier for the readers to identify one of the many themes that are embedded in Billy Budd.   Without these comparisons to Adam, the innocence and the tragedy of the downfall of Billy would not be as highlighted as they are in the story.   The reason for this is that it is this buildup that actually explains the demise of Billy Budd. While it is easy to compare the image of Billy Budd to that of a modern day messiah, it must also be pointed out that he was far from it.   The goodness that Billy espoused in his character was paralleled by the evil that he evoked from Claggart.   At the end of the story, the rage that consumes Billy and prompts him to smite Claggart is quite unlike that of the forgiving messiah who willingly gave up his life so that others may live.   There was goodness in Billy’s heart but there was also pain and confusion as he struck the mortal blow.   This is not the image of a messiah but rather the image of a victim of the harsh reality that is embodied in society. The sacrifice that Billy makes in the end becomes the haunting image of how a hostile society can corrupt the lives and minds of the innocent ones.   There is single person that can be blamed for the death of Billy.   Instead, Billy’s death was a result of all of the things that he had to experience in life.   There was never anything easy about the life of Billy.   It seemed that everywhere along the way there was something major that he had to decide on.   While ideally Billy was somebody to emulate, the experiences and the tribulations that he had to deal with were far from it.   In the end, there is nobody who can be blamed for the death of Billy but society itself because it was society which made the circumstances such and even, arguably, led Billy to his demise. There are no heroes in real life.   There are only those people who live their lives fully hoping that they can make a difference in this world.   The story of Billy Budd is about one of those individuals who live his life the only way he knows how yet is condemned by those who envy him.   As the Captain claimed, he was a good man who was condemned by bad law.   Billy may not be the hero that the world is looking for but he certainly ranks as one of those men who is worthy of respect and admiration.

It Takes Two to Tango Response Essay Example | Topics and Well Written Essays - 500 words

It Takes Two to Tango Response - Essay Example It is put into action in various situations ranging from petty, such as making a vacation rotation schedule to the life threatening ones such as renewing a contract with your suppliers or customers. Negotiations require the parties no matter the situation to reach an agreement point. Thus, when you decide to go into business with WSI, one should bear one thing in mind. The most fruitful outcome is one achieved during the negotiation process giving each party a correspondingly favorable deal. The main objectives for these negotiations will include certainty (Wankhede, 2013). Here is to record what it is that is being supplied, the standards of the commodity, the quantity of the product, magnitudes of delay and failure to exceed or meet expected requirements. It should also try to achieve the best deal by holding discussions of every element to ensure that both parties’ objectives are acknowledged. There should be the creation of a long-term relationship between parties and ensuring one achieves the organization objectives. Information research is necessary before engaging with a 3PL, and one must conduct a broad research on a number of issues (Wankhede, 2013). One is whether the firm is asset based as they make use of their warehouse, personnel and trucks to run their businesses. Management based make use of managerial and technological functions to run the function of logistics to their clients. The third type is integrated providers who mainly enhance their services according to customer needs. When the decision has been arrived at, the quotation (RFQ) and the request for information (RFI) ought to be detail as possible. The firm selected should accomplish the requirements of logistics that competing firm could also achieve. When engaging with a company like WSI there is the risk of emergence of potential issues that could result in very costly mistakes impacting negatively on your business. One should factor in the state of

SOCIOLOGICAL Essay Example | Topics and Well Written Essays - 5250 words

SOCIOLOGICAL - Essay Example These social topics are studied through complex theoretical and methodological frameworks that address the broad range of concepts like positivism and anti-positivism, social structure, individual agency, materialism, globalization, modernity, post-modernity etc. The social theories aid back to the ancient Greek civilizations. Social theorizing aided the Greeks in making sense of their lives, and in questioning the value and meaning of things around them. However, in the 20th century, social theories appeared as a distinct discipline and involved critical thinking in order to gain knowledge of social behaviours through posterior methods of discovery rather than apriority methods of tradition. In order to explain social phenomena, sociologists developed several theories. Sociological theories range from grand theories to middle range and highly specific micro range theories. It is extremely difficult to cover the aspects of these broad range theories, therefore in the later sections of this report; I will broadly give an outline of the dominant sociological theories and critically discuss two sociological theories in detail. i. Functionalism: functionalism is the oldest and the most dominant approach which has served as a building block in the development of sociology as a distinct decipline. Functionalist movement was most popular from 1940’s-1950 but reached its decline in 1960’s. Overall, this theory talks about two main aspects: Scientific methods should be applied to understand the â€Å"objectivity† of the social world. It says that social sciences can be learned in the same manner as natural sciences. Functionalists view this world as â€Å"objective real†. Therefore, they emphasized that scientific methods and statistical techniques can be applied to research social phenomena. However, the research should be value-free. It should not be affected by the values, principles and perceptions of the

Currency Act Essay Example | Topics and Well Written Essays - 500 words

Currency Act - Essay Example The government could decide to sidestep the initial referendum because of its own notion that such votes are not legally binding; in this respect it would be correct (Mendelsohn and Parkin 47-51). The fact remains, however, that the original Currency Act held that the pound sterling could not be changed as the official currency of Great Britain until a referendum had been held. By bypassing this element of the original Act, the British government could be held accountable for the changed currency in any way prosecutors saw fit. The change from the pound sterling into the weaker euro could mean that any number of businesses would face monetary challenges in the way of investment, wages and ultimately in profit; if the right people with the means to bring the issue up did so, the government would have to admit it simply ignored the referendum aspect of the original Currency Act. Despite the fact that an amendment or repeal to the Currency Act is, in effect, illegal without referendum, the establishment of the euro as the official currency of Great Britain would not be too difficult a feat if the government was decided on a course of action. This is particularly true because of the European Monetary Institute.

How does Steinbeck prepare us for the tragic ending in Of Mice and Men Essay Example for Free

How does Steinbeck prepare us for the tragic ending in Of Mice and Men Essay Steinbeck prepares us for the tragic ending in of mice and men right the way through the book. Lenny is the focus of all bad things to come and is a central character in the novel. First up there was the incident in Weed where Lenny stroked a womans red dress and she accused Lenny of raping her. This shows they make a habit of running away from places and people when Lenny often gets into trouble. an you aint gonna do no bad things like you did in weed neither. they run us outta weed. Those things show situations for the future and also show the dire situation they are in at the present, they are fugitives with Lenny committing the crimes and George helping him to get away because of their solid companionship in which both are each others only companions. The situation in weed also shows that Lenny likes stroking anything and anyone that is soft and once he has hold of someone or an it he cant let go. This is also shown with the mice where Lenny pets them too hard. uh-uh jus a dead mouse. He doesnt seem to fully understand the value of life nor regret his murders. This is not because he is malicious but because he is in fact mentally ill. His strength is beyond his control and this can create very dangerous situations for him and others around him, maybe even for-seeing murder here. The pups yet another example, this animal is also part of Lennys worrying fetish, here it is shown that he is too dangerous for even bigger animals in chapter five where he kills a pup. Lenny shows violence here towards the pups which he seems to love and have affection for, he thinks if the pup had not died (through no fault of its own) then George wouldve let him tend the rabbits and everything would be smiley again. All Lenny cares about is the rabbits and this predicts that maybe Lenny will do something destructive with the rabbits welfare In mind because he cares about them that much. Ill break their (anyone) god damn necks if they touch the rabbits he says defensively showing aggression. The bad mood Lenny is in sets him up to be calmed down by someone/something. Unfortunately this somebody/something appears to be Curleys wife. Curleys wife is another central character in the preparation of an all tears ending, she messes things for everybody and everything, I knew shed do us in the end George says resignedly after her death. She doesnt show any sign of stopping when she on her role of misery-making and it all leads up to a climax of some sort, and ending maybe to all the pain and suffering each and everybody is going through, putting their minds at rest. Curleys wife flirts as a meaning of talking to normal people, this is because she has not talked to other females and has not obtained any other skill so far in her short life, the men dont like her and thinks shes a tart because of this but still find her attractive and Lenny is no different in this respect, shes purty (pretty) he says with delight while looking at her body up and down, listening to her tender voice and looking at her silky hair, instantly she becomes an obvious unintentional target for Lennys animals like affections and the antics what go with this along with her red dress and red mule feathers which also attracts Lenny. When Curleys wife soothes Lenny and calms him down she doesnt know what shes letting herself in for, she thinks hes a harmless dum-dum. She talks to him in the first place because she is lonely and in return for listening to her Curleys wife lets Lenny stroke her hair which in turn triggers Lennys cant let go approach and he eventually kills her. We almost knew this was going to happen before it did because it resembles the weed incident too closely. Lenny had done a really bad thing George says. A mistake of the highest degree. The death of a human being had occurred. After this George doesnt even consider them going on the run together, here Steinbeck spells out the end of Lennys life indefinitely. George knows that Lenny cant get away with it and says we cant let him get away with it this time showing whats coming up next. Lennys death is now inevitable, George doesnt want Lenny to get hunted down and lynched like a wild animal but wants Lenny to die painlessly and dignified. This calls for Gorge to take control as anyway Lennys death is inevitable George decides to kill Lenny himself, humanely. Candys dog also showed signs of what happened to people who had no use in the ranch-place of work and it got shot just like Lenny would later be. If anything was learnt by the shooting of Lennys dog then it would have to be not to let a stranger kill someone who you care about. George deliberately took Carlsons Luger as he set out of to kill Lenny himself. Steinbeck also uses the scenery to prepare us for the death of Lenny, the surrounding are beautiful, day turns to dusk and everything is moving along swiftly. The wind picks up in the background and a heron takes off this signifies an event is about to take place. The reader always knew that Lenny would die at the brush because thats the place where he would go when he got in trouble and thats how George would find him. George sensed it was going to be needed early on in the novel again preparing us for the ending. In the end the cards mapped out the future in a sad way, while George was playing solitaire which again signifies their loneliness playing a one man game, Lenny picks up a card and asks why the card looks the same both ways up. George replies thats jus the way they make em. He is saying that you cant change what is inevitable just like Lennys impending doom. It is ironic that Lenny asks this question and George gives the answer because that is exactly what happens in the end.

Gender Differences in Multitasking: Texting During Lectures

Gender Differences in Multitasking: Texting During Lectures Today, the communication technology has been growing widely to the extent that we can communicate with each other anytime and anywhere. As long as there is Wi-Fi or network coverage, our smartphones, tablets or computers can be used as a communication tool or a gadgets for us to receive new information in the world. Consequently, this function is so easily accessed by all, we are able to receive text messages, phone calls, emails and social network notifications throughout the whole day. However, this can be either a blessing or a curse. As we are exposed to all these information and entertainments, these can be a distraction in our daily tasks. To be specific, students in college are able to access to all these functions most of the time, it has pushed students to multitask more often in their daily lives. These might interfere with their studies as multitasking involves in switching tasks from one and another as well as the attention (Judd, 2013). In a study done by Wilkes University, 95% of the students bring their phones to college every day and 91% of the students admitted to using their cellphones during lectures (Harris, 2013). This has shown that most students tend to multitask in class as they listen to the lecture and use their phone at the same time for either text messaging, social networking or any other purposes. However, research on multitasking have proven that the human has no ability to perform more than one overlapping task at the same time due to the interference occurs in human information processing system (Levy Paschler, 2001; Wood et al., 2012). In other words, students can hardly concentrate in class if they are using their phone at the same moment. This explanation is consistent to the findings of Bowman, Levine, Waite Gendron (2010) that students who instant message while reading take longer time to finish the task. For generations, the stereotype of women are better at multitasking is debated across the world. Although scientist in University of Pennsylvania has supported this statement by discovering females’ brains are connected from left to right, while men has more intense movement in certain part of the brain (Spencer, 2013), many research done on multitasking has rejected the idea. Buser and Peter (2011) reported that women suffer as much as men while multitasking and have no significant differences in productivity of tasks. Not only that, even Conner, Laws, O’Connor and Stoet (2013) found that women outperform men in multitasking, they pointed out that their results cannot be generalized as the empirical studies on gender differences in multitasking is insufficient. Theoretical Framework Living in this world where we are overwhelmed by all perceptual information, our human information processing system can detect, recognize and identify chunks of stimuli at the same time (Hedge, 2013). As so, in this context, attention has given the model a function to either enhance or inhibit information, in other words, our attention chooses which certain information for further processing or ignore (McClelland, 2007). However, when two information are presented and are asked to process at the same time, the ability to attend both fully will be impaired as there are insufficient capacities in the information processing system; this attempt of trying to focus on multiple stimuli at one time is also known as divided attention (McClelland, 2007). One of the example of divided attention is multitasking, which can be defined as performing more than one task simultaneously or switching from one task to another back and forth (APA, 2006). In the human mind, multitasking is managed by a process called executive control; and to decide which cognitive processes and when it is performed, the executive control system will go through two stages – the goal shifting (decision of what to do) and role activation (action of switching task) (Meyer, Evans Rubinstein, 2001). Hence, people tend to repeatedly switch between tasks to achieve two things at a time without constant awareness; although it might seems productive and efficient, it is explained that multitasking leads to more mistakes and more time consumed as there will be brief mental blocks during switching of tasks (Meyer, Evans Rubinstein, 2001). Past Research Many past research have shown that multitasking in class can lead to poor academic performance. Junco (2012) conducted a research examining the relationship between in-class multitasking and academic performance, by giving out survey forms to a large number of students (N = 1,839) measuring their technology usage in class and internet skill to be compared to their grade point average (GPA). He then reported that constant multitasking in class (which include surfing social networking website, chatting and text messaging) has a significant negative correlation with students’ over semester GPA (Junco, 2012). Additionally, Carrier, Cheevar, Lim and Rosen (2011) did an experimental study on the frequency of text messaging interruption during a lecture has found that students in High texting group (16 messages or more) scored significantly lower than the Moderate texting group (8 to 15 messages) and No or Low texting group (0 to 7 messages) in the quiz after a 30 minute videotaped l ecture. Through the cross-cultural analysis of surveys results on mobile phone etiquette and multitasking in class, it showed that Americans and Chinese students both believe using cellphone in class will not interfere their learning but Americans students find it more appropriate to text in class than the Chinese; additionally, no gender significant difference is found (Rosenfeld, 2014). Many other research have furthered this study by doing an experimental study on multitasking in class with the awareness of cellphone distraction. Even many students did not believe that using their smartphones in class is a distraction from their learning, the scores of the short quiz given after the same lecture between students who use cellphones in class and students who listen to lecture without cellphones have a significant difference where students who anticipate in communication technology have a lower score (Elder, 2013). This result is consistent to the findings of a mixed experimental study on th e relationship between self-regulation, attention and cognition learning ability in classroom learning, which reported that college students who constantly self-regulate tend to have a better cognition learning by sustaining their attention during lecture as they text less (Klausner, Wei Wang, 2012). Besides, during an accounting principle lecture in Columbus State University, the half of 62 students who are allowed to multitask in class in the form of communicating with each other through texting did worse in the exam than the other half of students who are not allowed to use their cellphones during lecture (Ellis, Daniels Jauregui, 2010). Although in this study they did a comparison between male and female, they found that gender has no significant impact on learning ability without taking account of whether they multitask or not (Ellis, Daniels Jauregui, 2010). This research is similar to a recent experimental study which both groups of psychology students, who are asked to text and to switch off their phones during a short 20-minute lecture, are then given a short quiz to test their learning ability; the researchers concluded that texting in class is a strong distraction during lecture like other past research, but no gender comparison is done (Dietz Henrich, 2014). Howeve r, in the research of gender difference on multitasking have shown that women suffer as much as men in divided attention while completing multiple task at the same time and choose to avoid multitasking upon free will (Buser Peter, 2011; Strayer, Ward Watson, 2013). Description of Study Although many research has done on student multitasking capabilities in class (Carrier, Cheever, Lim Rosen, 2011; Ellis, Daniels Jauregui, 2010; Gingerich Lineweaver, 2013) and gender differences in multitasking (Buser Peter, 2011; Conner, Laws, O’Connor Stoet, 2013), there are limited research that compared male and female students’ academic performance if they multitask in class. In this study, we will be examining the gender difference in multitasking during a lecture. The aim of this experimental study is to see whether male or female students can multitask better while learning. All participants recruited for the study will be separated to different groups based on gender and will undergo one experiment each, either texting during lecture or no texting during lecture. As all participants will have to attend a half an hour English Literature class, the no texting group will not be allowed to access to their cellphone. However, for the texting group, each participant will receive a text message every 5 minutes and is required to reply. At the end of the experiments, all four groups of participants will be given a quiz to test their understanding of the lecture. Based on Carpenter et al. (2012) and Ellis, Daniels and Jauregui (2010), we hypothesize that texting in class will lead to a poorer performance in the quiz. Then, based on Buser and Peter (2011) and Strayer, Ward and Watson (2013) on gender differences in multitasking, we hypothesize that there will be no differences in both gender on performance in quiz for texting during lecture. Method Design The independent variable of this study is gender differences in multitasking, with two levels, male and female; the dependent variable is quiz scores. This is a between subject design as the participants will be separated to different groups and only go through one experiment either texting during lecture or no texting during lecture. Participants Approximately 80 male participants and 80 female participants, from all races, will be recruited from different private colleges in Penang for the experiment. This is because all the past research used participants less than this amount. A total of 62 participants of both gender are tested on the study by Ellis, Daniels and Jauregui (2010); and a total of 67 participants are used in the study of Gingerich and Lineweaver (2013). The age of the participants will be 18 to 25 (M = 21.25), which most people in this age attend college. The participants are recruited through purposive sampling where they have to meet the 2 following criteria, enrolling in an undergraduate program and is able to understand English perfectly. The students will be participating the experiment voluntarily. Materials A half an hour lecture of English Literature Studies will be given to all participants. As the participants recruited are from variety of courses, this is to ensure that the students have not been to the lecture before and have no prior knowledge in it. At the end of the experiment, a 20 multiple choice question quiz based on the lecture will be given to the participants to answer. As for the treatment group, a total of 6 text messages will be send to the participants which consists of basic conversation questions, such as â€Å"What is your hobby?† Procedure This experimental study will be done in a big lecturer hall with a clear projector screen and perfect sound system. Before the experiment is conducted, all the participants will be asked to sign the inform consent form. After that, they will be divided into four groups, the male control group, the female control group, the male texting group and the female texting group. The students will be told whether or not they are receiving text messages. For all four groups of experiment (the female control group, the male control group, the female texting group and the male texting group), the lecturer and the English Literature lectures given will be same. However, on the treatment group for both genders, each participant will receive a text message every 5 minutes and they are required to reply the message before the next message comes. After the 30 minutes lecture is finished, all participants will be asked to take a short multiple choice questions quiz based on the class conducted. Once the students have finished the quiz, they are allowed to leave. Statistical Analysis As this experimental study only consist of one independent variable and one dependent variable, the data will be analyzed using SPSS with independent one-way ANOVA; and to see if there is significant differences between two means of independent groups. History: The Act Of God Defence History: The Act Of God Defence The Law of Tort is a developing and ever dynamic field and is a conception evolving through centuries. This field is used with principles under which tortuous liability can be demanded. Simultaneously, certain other principles are used, to oppose these claims for compensation. These counter claims, or defences are used to evict those innocent citizens from tortious liability who have been unfairly implicated with claims imposed on them. These defences were framed from time to time to keep up with the very basis of imposition of tortious liability on an individual- i.e, creating a sense of deterrence while keeping up with the basic values of justice. One such defence which will be discussed elaborately with cases subsequently is ACT OF GOD. MEANING Act of God means an event which happens independently of human action such as death from natural causes (Actus dei nemini facit injuriam), storm, earthquake, tides, volcanic eruptions etc., which no human foresight or skill could reasonably be expected to anticipate. For example, damage from a tornado or a lightning strike would be considered an act of God. Damage would not be considered an act of God if it is caused by the property owner. Vis is a Latin word meaning any kind of force, violence or disturbance to person or property. Vis major is an act of God. The doctrine states that a person is absolved of liability if it was directly caused by vis major. LEGAL DEFINITION Act of God was first judicially defined in Tennet v. Earl of Glosgow Lord Westbury, was first recognised by Blackburn J. in Rylands v. Fletcher and was first applied in Nichols v. Marsland and many other cases. Blacks Law Dictionary defines an act of God as An act occasioned exclusively by violence of nature without the interference of any human agency. A natural necessity proceeding from physical causes alone without the intervention of man. It is an accident which could not have been occasioned by human agency but proceeded from physical causes alone. Vis major is similarly defined, as A greater or superior force; an irresistible force. A loss that results immediately from a natural cause without the intervention of man, and could not have been prevented by the exercise of prudence, diligence, and care. According to Salmond act of God includes those acts which a man cannot avoid even by taking reasonable care. Such accidents are are the result of natural forces and are incoherent with the agency of man. Thus it is an act which is due to natural causes directly and exclusively without human intervention, and that it could not have been prevented by any amount of foresight and pains and care reasonably to have been expected from him i.e. the defendant . Accor ding to Lord Mansfield, it is something in opposition to the act of man. Conclusion: It has been said that it would be probably never be capable of complete, exact unassailable definition. But it has also been said that this untheological expression is well understood by lawyers. It is such a direct, violent , sudden act of nature that no man could forsee and if he can, he cant prevent it. ELEMENTS NATURAL CAUSES An act of God is an uncommon, extraordinary and unforeseen manifestation of the forces of nature, or a misfortune or accident arising from inevitable necessity. An act of god cannot be prevented by reasonable human foresight and care. The effect of ordinary natural causes may be foreseen and avoided by the exercise of human care. For example, the fact that rain will leak through a defective roof is foreseeable. In case of foreseeable causes, failure to take the necessary precautions constitutes negligence, and the party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences. Therefore in such cases the injured party has no right to damages. Acts of god are generally attributable to forces of nature. They are generally in the nature of accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms. Snowstorms of great violence have been held to be acts of God. Whether freezes are acts of God depend on the locality and season of the year in which they occur, i.e., their foreseeability is affected to a greater extent than other natural occurrences by these factors. Catastrophic earthquakes and volcanic eruptions should be defined as acts of God since they measure up to the accepted definitions of act of God in every respect. However, fires are generally not considered acts of god unless they are caused by lightning. Whether or not a particular natural event warrants such an adjective is a function of such things as the intensity of the event, characteristics of the area, and climatic history. UNUSUAL VIOLENCE- BOTH SUDDEN AND IRRESISTIBLE AN OCCURRENCE NOT REASONABLY FORSEEABLE The basic and prime element of an act of god is the happening of an unforeseeable event. For this, if the harm or loss was caused by a foreseeable accident that could have been prevented, the party who suffered the injury has the right to compensation. However, the damage caused by an unforeseen and uncontrollable natural event is not compensable as it could not have been prevented or avoided by foresight or prudence of man. Moreover, courts are of the opinion that the act of God defence exists only if the event is so exceptional and could not have been anticipated or expected by the long history of climate variations in the locality. It is constructed by only the memory of man i.e. recorded history. The courts may even demand expert testimonies to prove that an event was unforeseeable. IMPOSSIBLE TO PREVENT BY ANY REASONABLE PRECAUTIONS AND ABSENCE OF HUMAN AGENCY CAUSING THE ALLEGED DAMAGE It means practically impossible to resist. Negligence constitutes failure to take the necessary precautions. In an incident where a human factor was present, even though the harm could not be prevented, the fact that the human factor exercised reasonable care and precautions to prevent the harm has to be proved if the defence of act of God has to prevail. If negligence is alleged and proved, the defence of act of God will fail. If a home owner was negligent in properly maintaining a tree that fell on a passerby, he cannot be exempted from liability by act of God principle. In Clark v. Multnomah, the Court made a decision that the flooding of a house was not an act of God where it was caused by the breakage of a pipe fitting in the house. The cause of harm was evidenced by the fact that a repairman had worked with the part that broke just hours earlier. ESSENTIALS There must be operation of natural forces like exceptional rainfall, storms, tempests etc. without any human intervention. The incident must be extraordinary and not which could be anticipated and reasonably be guarded. ORIGIN HISTORICAL EVOLUTION The term act of God occurs and is described in holy texts dating back to the 13th century, specifically referring to acts that God has undertaken. The act of God referred is that which is used in legal and insurance circles when discussing any act which is outside human control and governance and therefore not the responsibility of any individual or corporation. The term was first used in this way in the mid-19th century. Peter Simmonds Dictionary of Trade Products, 1858, uses the term: Force-majeure, a French commercial term for unavoidable accidents in the transport of goods, from superior force, the act of God, etc. In July 1803, The Times included this legal ruling given in a court case by Lord Ellenborough, which is in terms that we are now familiar with from our own household insurance policies: By Common Law, Carriers are insurers against every loss of property entrusted to their care, except losses arising from the Act of God, or the Kings enemies. Earthquakes, floods, hurricanes, tornadoes, wildfires, drought and a deadly tsunami are a long series of natural calamities of seemingly large proportions have been witnessed by us . Lives are lost, properties destroyed , and emotions shattered when these forces of nature tragically strike. The natures blow may be so intense that it may come as a total shock and baffle both to the direct victims of the disaster and, subsequently, to the accused tortfeasors Defendants are quick to claim act of God as a defence to these lawsuits. For three centuries, the act of God defence has been accepted in negligence and strict liability cases. Act of God, as a legal concept shows up not only as a defence, but also in discussions of duty and causation. At first glance, the act of God defence seems a simple, direct concept with few gradations or intricacies. Consequently, all too often, many lawyers have misused the phrase act of God to mean any unfortunate act of nature. In a sixteenth century opin ion, in the Shellys Case best known for the famous property law doctrine, the court wrote in terms of performance becoming impossible by an act of God, which was the death of one of the parties. In an attempt to give life to this notion of fairness, the courts in Shelleys Case and other early decisions drew lines between those acts which were natural and those which were caused by man, so as to forgive man for those acts that were beyond his anticipation or control. The court stated: It would be unreasonable that those things which are inevitable by the Act of God, which no industry can avoid, nor policy prevent should be construed to the prejudice of any person in whom there was no laches. No further explanation of the phrase, Act of God, was provided by the court. The phrase again appeared in the 1702 case of Coggs v. Bernard, which invoked liability for a bailment by a common carrier. Justice Powell opined that a bailee shall answer accidents, as if the goods were stolen; but not such accidents and casualties as happen by the act of God, as fire, tempest for the bailee is not bound, upon any undertaking against the act of God. The act of God defence expanded from common carriers into other areas of strict liability. The Courts then extended the act of God defence to cases of negligence. The act of God defence received prominence in decisions construing the common-law liability of common carriers who were treated as insurers of the goods they carried. In 1785, Lord Mansfield delivered a unanimous opinion in Forwardv. Pittard which involved an accidental fire for which the carrier was in no way at fault. The court clearly established a rule of strict liability for common carriers: It appears from all the cases for 100 years back, that there are events for which the carrier is liable independent of his contract. Again, in Forward, the English courts limited the act of God defence by excluding acts of man. In addition, the burden of proof was shifted from the plaintiff to the defendant to establish the existence of the act of God defence. Although the courts subsequently split on the liability issue for common carriers whose delay subjected its freight to damage from an act of God, there was a consensus that liability would result if the common carriers knew that the force of nature was coming. CASE LAW: In Nichols v. Marsland(1875)( Discussed in judicial cases section) APPLICATION Act of God is often a difficult defence to establish. It requires both the exclusion of human agency and unforeseeability to establish an act of God. For an event to be a legal act of God, the natural event must have been the sole and immediate cause of the injury, with no co-operation of man, or any admixture of human means. Generally speaking, then, the vis major defence can apply to a case involving damage or harm by a natural force, but only in circumstances in which that force is strong enough to overcome and nullify any potential contributory cause by a human agency. The issue is whether the magnitude of force is reasonably foreseeable such that a defendant should have taken precautions to avoid personal injury or property damage resulting from it. For example, a 55-mile-per-hour wind gust, though rare, is reasonably foreseeable in Wisconsin. However, a 200-mile-per-hour tornadic wind is probably not; the vis major defence would apply to personal injury or property damage caused by such a force, even if a human agency (for example, a product such as a window or door) was involved. With respect to rain: An hourly rainfall of three inches, while heavy, is not unforeseeable in Wisconsin; an eight-inch hourly rainfall probably is. A basement collapse would probably implicate the vis major defence in favour of a basement contractor in the latter circumstance but not in the former circumstance. When property damage or personal injury is caused in part by a natural force and in part by a human instrumentality, the plaintiff should argue that the natural force was foreseeable and should have been anticipated in a manner that would have avoided the damage. The defendant then has the burden to establish that the natural-force component of the cause was so huge and so monumental that it was not reasonably foreseeable. The point is that the occurrence of natural phenomenon need not be unique, nor need it be one that happens for the first time; it is enough that it is extraordinary or exceptional and so as it could not be reasonably anticipated and also it must be free from human conduct. The word vis major imports something abnormal and with reference to the context means that the property by the act of God has been rendered useless, for the time being i.e. it was rendered incapable of any enjoyment. Vis Major to afford a defence must be the immediate cause, the causa causans, and not merely a causa sine qua non of the damage complained of. The mere fact that vis major co-existed or followed on the negligence is no adequate defence. Before an act of God may be admitted as an excuse the defendant must himself have done all he is bound to do. The legal maxim Actus dei nemini facit injuriam means the Law holds no man responsible for the act of God. The important thing in regard to vis major is not the positive intervention of natural forces but a process of nature not due to the act of man and it is this negative side which deserves emphasis. It is thus a negation of liability. Complete exclusion of human cause is a difficult standard for a defendant to overcome, which likely explains why the defence is not commonly argued or upheld. As a result, modern courts sometimes characterize acts of God as unavoidable accidents because, although the terms often are synonymous, unavoidable accidents need not be free from human agency. ACT OF GOD AND INEVITABLE ACCIDENT DISTINGUISHED Every act of God is an inevitable accident but not vice versa. An Act of God is discrete and distinct from inevitable accident. In order that an accident may be an act of God it must have followed directly from natural causes without human intervention. In Nugent v. Smith, Cockburn, C.J. said All causes of inevitable accident, casus fortuitous meaning an uncontrollable accident, may be divided into two classes: Those which are occurred by elementary forces of nature not connected with the agency of man or other cause [Act of God] Those which arises either wholly or in part by agency of man. [Inevitable Accident] Example- 1. If a ship is pushed ashore by a violent storm, this is the Act of God; but if it is run ashore during a fog by mistake, however unavoidable on the part of captain, this is the act of man. If a building is set on fire by lightning, this is an act of God; but not so if it is done by human through falling of a lamp even though this was due to no negligence. INEVITABLE ACCIDENT ACT OF GOD Could not be prevented by the exercise of ordinary care, caution and skill A direct violent, sudden and irresistible act of nature as could not, by any amount of human care and skill have been resisted is Act of God. May be controlled by human beings 2. Not controlled by human beings. 3. Strict liability can be imposed on the tortious liability occurred due to inevitable accidents 3. Even strict liability can also not be Imposed in cases of torts arising out of acts of Gods 4. The courts have discretionary power in determining the defendants tortuous liability 4. No discretionary power Conclusion : The defence of inevitable accident is a more general defence and is distinct from the act of God in so far as it is dependent on human agency and not on natural forces and in the degree of unexpectability. ACT OF GOD NEGLIGENCE Negligence, in law, especially tort law, is the breach of an obligation (duty) to act with care, or the failure to act as a reasonable and prudent person would under similar circumstances. Both these defences (act of God Negligence) are based on reasonable foreseeability. In terms of foreseeability, the question is not whether a similar event has occurred before, but whether the risk that this particular mishap may occur is foreseeable. Thus, a flood, earthquake, hurricane, or other natural force need not have previously struck a particular location for negligence to exist. Liability may still exist if reasonable design, construction, operation, inspection, or maintenance. For a plaintiff to recover damages, this action or failure must be the proximate cause of an injury, and actual loss must occur. In cases of joint causation, where both human negligence and act of God have a role to play, the traditional sine qua non (but for), substantial factor, or legal causation tests apply. If the act of God is so overwhelming that its own force produces the injury independent of the defendants negligence, then the defendant will not be liable. If the damages suffered are incurred solely due to natural causes without any known fault, there is no liability because of the act of God. There are two ways of viewing this situation. The act of God either supersedes the defendants negligence, or the defendants negligent act is not a cause in fact of the injury. In either case, the defendants act did not cause the damage since the injury would have occurred anyway. The party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences; hence, the injured party has no right to damages. Accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms are usually considered acts of God, but fires are not so considered unless they are caused by lightning. JUDICIAL CASES Nichols v. Marsland  [1]   In this case, The defendant had constructed certain artificial lakes on her land by damming up a natural stream at appoint higher up than the defendants land. An extraordinary rainfall, greater and more violent than any within the memory of witnesses, caused the stream and lakes to swell to such an extent that the artificial banks burst and the escaping water rushed on to the plaintiffs land and carried away four county bridges. Nichols, the plaintiff brought an action for damages on the plea that the defendant was liable under the rule in Rylands v. Fletcher  [2]  . HELD: The contention was rejected and the defendant was held not liable. The Court of Exchequer Chamber held that she ought not to be liable for an extraordinary act of nature which she could not reasonably foresee. It was said that one is only bound to provide against the ordinary operations of nature, but not against her miracles. Greenock Corpn. V. Caledonian Railway Co.  [3]   The facts were that the corporation in laying out a park constructed a pool for children in the bed of a stream and there altere its course and obstructed its natural flow. Owing to rainfall of extraordinary intensity, the stream overflowed at the pond and great volume of water poured down a streetand flooded down the property of a railway company. HELD: It was held that this was not damnum fatale and the Corp. was liable. Nichols case was distinguished on the ground that in that case it was the storing of water in a reservoir and not with interference with the course of natural stream and that anyone who does interfere with it must provide against even an extraordinary rainfall. State of Mysore v. Ramachandra  [4]   In this case, the State had constructed a reservoir for the supply of drinking water for the villagers of Nipani. But the construction was not completed and the over-flow channel linked with reservoir was partially constructed. Land and crops were damaged due to flow of water resulted from rain. The plaintiff filed the suit for damages. HELD: The State resisted the suit that it was the act of God. But, the court rejected the defence and observed Assuming an act of God such as flood wholly unprecedented, the damage in such a case results not from the act of man in that he failed to provide a channel sufficient to meet the contingency of the act of God. But for the act of man there would have been no damage from the act of God. T. Gajayalakshmi v. Secretary, PWD, Govt. of T.N.  [5]   The deceased, a cyclist, who was going on his way was electrocuted by the falling of an overhead electric wire. HELD: The court rejected the contention of Electricity board that it was an unexpected event due to rain and wind and that the snapping of the electric wire was an act of God. It also rejected the plea that the death took place due to the negligence of the deceased in his leaving the home that day in rain and wind. Mahindra Nath Mukherjee v. Mathuradas Chaturbhuj  [6]  . A cinema advertising board was placed on the roof of the defendant which fell down and injured the plaintiff. Plaintiff brought a suit against the defendant and contended that the board fell due to storm of unusual severity. But, it was observed that during the season of monsoon a storm of this magnitude is not uncommon. The defendant had not ensured or foresee that the fixing of banner on such a height is strong enough to face the pressure of storm during monsoon season. The Calcutta High Court held that such a storm cannot be said to be so unexpected that no human foresight could reasonably be expected to anticipate it and cannot be regarded as vis major or act of God. Hence, the suit was allowed and the defendant was found negligent. Before the act of God can be admitted the defendant could have taken reasonable care and done all that what he was bound to do. Kallulal v. Hemchand  [7]   The defendant constructed a building and it was collapsed and as a result of it, two sons of the plaintiff were dead. Before the day the building collapsed there was a heavy rain. The defendant pleaded the rain as an act of God HELD: The court observed that the Acts of God must be apparent on the face of the records. They must be known and affect largely to entire public. The defendant was held liable. The act of God or vis major can also be explained mathematically as follows: (i) Unprecedented + Unforeseen + Irresistible = Act of God (As it has been discussed in this Chapter in the cases Nichols v. Marsland; Mahindranath v. Mathura Dass) (ii) Unprecedented + Foreseen + Irresistible + Act of God (Nichols v. Marsland case) (iii) Precedented + Unforeseen + Irresistible = Act of God (Greenock Corporation case) (iv) Precedented + Foreseen + Irresistible = Act of God (Greenock Corporation and Mahindranath cases) EXAMINING ACT OF GOD PRESENT SITUATION Vis Major as a defence depends on two ; lack of predictability and lack of control. If either criteria is missing, the defence fails. Both were solidly based for centuries on the lack of scientific knowledge. Man not only lacked the ability to predict the forces of nature, but also the ability to guard against, control, or otherwise minimize their impacts. In the words of the ancient mime writer Publilius, it is vain to look for a defence against lightning. Today, foreseeability is based not only upon the past, but also upon that which modern technology and science allow us to project into the future. Science has advanced to the point where we can understand many forces of nature, such as precipitation and flooding. Historically, we know which areas have been subjected to specific forces of nature. Scientifically, we can predict the areas which may be subjected to such forces. At first glance, the act of God defence should continue to play a role in strict liability cases. Part of th e underlying purpose of the act of God doctrine was to ameliorate strict liability. In strict liability a number of exceptions have evolved. Whether a particular occurrence amounts to an Act of God is a question of fact, but the ambit of this defence is somewhat restricted. Increased knowledge seems to limit the unpredictable. Natural hazards are no longer a mystery to us. Hence, the applicability of the act of God defence has shrunk in inverse proportion to rapidly expanding concepts of foreseeability. Conversely, environmental changes at the global level have left some scope for Vis Major as a defence. Unforeseen disasters like the July 26, 2005 floods in Mumbai or the devastating Tsunami on 26 December 2004, which was the result of severe earthquake with its epicentre at Indonesia can still be attributed to acts of God. These disasters were completely unforeseen and any prior intimation about the same would not have helped bring the situation under control. Such natural catastrop he has left some scope for the use of Act of God as a defence. Flaws in The Common Laws Approach to The Act Of God Defence 1. The Problem of Increasing Event Foreseeability In terms of Event Foreseeability, there are two independent trends which suggest a strong possibility that climatic events which historically qualified as Acts of God may become increasingly foreseeable: improved meteorological techniques and the effects of climate change. It is undeniable that there is increased data available and increased forecasting powers inherent in the continuing development of meteorological science. This trend has two impacts on the foreseeability of such climatic events for purposes of the Act of God defence: (1) defendants can increasingly know that the hurricane or storm is coming with time to take some precautionary steps in response because they will be warned of it (so that it will be more difficult to say that the event was unexpected or unanticipated); and (2) climatic data of past storms will continue to accumulate (so as to support conclusions that the event is not unusual for the location at that time of year). In short, the climatic events which historically may have been considered Acts of God will be more foreseeable in the future and thus less likely to support the defence simply because we will know more and more about the weather. In short, as climatic change increases the frequency and intensity of hurricanes, heavy storms, and the flooding associated with such climatic events, it appears that it will be harder for defendants to claim that the events themselves or the consequences of those events were not foreseeable. Thus, the defence is likely to be diminished in its utility simply because it will be harder to satisfy the legal requirements relating to the Event Foreseeability necessary to invoke the defence 2. The Problem of Response Forseeability As the climatic events themselves become more foreseeable, Response Forseeability becomes more critical to the Act of God defence because the burden is on the defendant to show that it took reasonable precautions in light of the foreseeable risk. It is here that foreseeability in the context of the Act of God defence really breaks down because of the inability of the defendant to foresee what the adequate response is before the climatic event occurs. To illustrate the problem, consider a fact pattern taken from the Act of God case law: a warehouseman holding goods for a customer in a Gulf Coast state in which a hurricane could strike. Given that a significant climatic event (i.e. a hurricane in the Gulf) is foreseeable, the court will have to analyze whether the defendants actions were reasonable in light of the foreseeable risk. CONCLUSION Although the act of God defence that a defendant is insulated from liability for personal injury or property damages caused by a natural cause is rarely used, it may become more common and general in the future if predictions of disastrous weather events caused by global warming prove true. One prediction related to global warming is that catastrophic weather events such as hurricanes, tornados, and torrential rains will occur more often. All of these have the potential for causing extensive personal injury and property damage and consequently mental trauma. Therein lie the core for more frequent, common and general use of the vis major defence. Is it still viable? How might it apply as a defence to tort? The act of God defence is as common today as ever. Though, it is still not relied on very often, likely because of the difficulty of proving that human elements played no role in causing an injury. The potential application of vis major will expand if meteorological predictions concerning climate change through global warming come to accomplishment and realization. However, as these events become more common, the standard of what constitutes a reasonably foreseeable natural force will doubtless itself expand. This again would confine application of the vis major defence insofar as defendants become obligated to anticipate and account for effects of more extreme and dangerous natural phenomena, especially those associated with the weather. However, in the era of global climate change, courts can hardly pretend that causation can be determined to be natural or human. Storm patterns and frequencies are changing. Growing seasons are shifting. Glaciers are melting and seas rising. Global climate change will present courts with the kinds of difficult factual situations that make it impossible to pretend the old act of God divide should stand untouched. Even though a particular defendant in a given case may not have been demonstrably at fault, the act of God doctrine remains analytically flawed because it requires that nature be the sole cause of a phenomenon to the exclusion of all human action