Often Times People Tend To Look At A Work Of Art And Only See A Essays

Often times people tend to look at a work of art and only see a picture. Later, if one looks closer a clear message or meaning is depicted by the artist. Thomas Hart Benton's work, Cradling Wheat, for example is just a picture at first glance, but as one examines the painting closer, the story behind it becomes evident. This tempera and oil on board composition illustrates four men in a field threshing and bundling wheat. Benton draws the viewers eye forward by placing the characters in the foreground of the work and the surrounding landscape in the back. Here, the American artist presents the focal point he intended. The faces of the men in the piece are all hidden by hats, distance, or turned backs. By hiding their faces the conclusion can be drawn that these men are hired hands. Benton emphasizes the type of men by presenting them in similar clothing. All dressed in charcoal trousers and sky-blue work shirts, they appear to be wearing uniforms. Perhaps the artist feels that most farm hands were no-named and insignificant and expresses his opinion by giving them these characteristics. Assumable is the fact that the painting depicts times before electricity and the invention of motors because the men are using hand tools to cut and bundle the wheat. Included in the focal point, of course, is the wheat. Benton combines texture and a vivid shade of tan to bring the wheat field to life. While the texture of the wheat is definite, it is also soft, creating the effect of a light breeze in the Midwestern scene. The brightness of the color of the wheat also adds to the 3 atmosphere created by the artist. While the background sets a certain mood, the brilliance of the wheat helps define the type of day Benton wanted to portray-a hot, summer afternoon. In addition to the wheat, a few small wildflowers are scattered throughout the field. The philosophy behind the dispersed blossoms suggests a break in the monotony of constancy. There is a constancy of wheat and a constancy of labor and while the clever, American artist is aiming to show the life of a farmhand, he added the flowers to simply break up the invariability. The secondary part of the composition, the background, does nothing more than set the mood or atmosphere and provide a specific landscape for the work. Closest to the focal point is a line of trees and foliage which separates the wheat field from another field. The use of the dark emerald vegetation emphasizes the certainty that the scene is on an immense farm. Behind the wild foliage is another spacial field of a light shade of green. By adding this field, Benton implies that the farm grows a variety of crops, but again, it chiefly adds to the landscape and little more than that. Following the light green field is yet another field. It appears to be a second wheat field of a darker shade of tan. The tawny hue of this field gives a shaded effect achieving a distant air. While most of the background exclusively sets the scene, this subsequent wheat field also seems to signify the vast workload

Shakespere essays

Shakespere essays In Much Ado About Nothing, most of the characters had interesting relationships with each other. For example, Hero and Claudio, were deeply in love. Also, Don Juan, and Don John were fighting with each other. Another example was the close friendship between Benedick, Claudio, and Don Juan. But the relationship between Benedick and Beatrice was different than the others. In their relationship, they hated each other, that brought them together. Their personalities were so similar, that it made them sick of each other, but the similarities in their personalities is Benedick was a smart, good-looking, and funny guy. He was very witty, and always had a response to anyone's comments. For example, when he was talking to Beatrice, he always had a comment to finish of the conversation. He also didn't like the idea of marriage. Benedick thought that marriage led to the trapping of men. When he heard about Claudio getting married, Benedick thought that Claudio was crazy, because Benedick felt that marriage was going to change the way Claudio lived. Benedick was also very stubborn. He never wanted to give into other people's ideas, and that was why he didn't want to give into the idea that marriage could be a good thing in a person's life. Beatrice was a character very similar to Benedick. She was a very independent person, and didn't want to rely on anyone for support. She also was very smart. She enjoyed reading poetry, and thought about things a lot. She also was against marriage. During one conversation, she even said that she would rather die than get married. Another characteristic of Beatrice was that she was very emotional. She often changed her mood all of a sudden for no apparent reason. Also, Beatrice kept many of her feelings inside her. Sometimes she would be angry but ...

Evernotes Beat Buhlmann How I became the CEO of my own life

Evernotes Beat Buhlmann How I became the CEO of my own life Evernote's Beat Buhlmann: "How I became the CEO of my own life" Beat Buhlmann is the General Manager of Evernote EMEA. With ten years of life management coaching under his belt, he decided to write a book about personal development planning and how it can help people manage their work goals and personal lives simultaneously. His book, Become the CEO of Your Own Life, was published earlier this year, an achievement that Beat credits in part to two time-saving friends to authors: Evernote and Reedsy. Read on to learn how these two tools came into play during the writing process, and to learn more about Beat's strategies for taking control of personal and career development.How did you get started on writing your new book, Become the CEO of Your Own Life?Working so intensively in the field of life management coaching was not my plan when I set out to start my career after graduation. As I began working, I quickly realized the importance of distinguishing between people management and business management. I also realized the importance of allowing an d encouraging individuals to accomplish goals not only professionally, but also in their personal lives - both parts are important if you want to create an environment of trust in the workplace.However, in today’s rapidly changing and hectic workplace laden with distractions and constant overload, managing one’s own life can be a challenge. To this end, I created a personal development plan (PDP) called the Swiss PDP Approach ®. For several years, I coached companies such as Dell, Google, and Evernote implement the Swiss PDP Approach ® to support their teams’ efforts to combine and align private and business life in an effective and meaningful manner. In today’s workplace laden with constant overload, managing one’s life can be a challenge. The Swiss PDP Approach ® is a simple approach but it works well, and I was getting increasingly more requests from Google managers around the world to hold people development training sessions for their teams. However, there came a point when I could no longer keep up with the demand - I still had a full-time job. I ended up having to to say â€Å"no, sorry† to many people, which was a difficult task, as turning down meaningful opportunities went against my inner beliefs. The first person whose request I declined was Matt Brittin, EMEA President at Google. It was Matt who encouraged me to write a book to share and spread my Swiss PDP Approach ®. So I did.What is the Swiss PDP Approach ® and how can it be applied to writers?One of the key elements of the Swiss PDP Approach ® is its non-silo approach. Far too often, people raise a wall between their private life and their work life (creating two silos). However, that does not make sense - what happens in your private l ife has an impact on your work life and vice versa. Therefore, I suggest a holistic, integrated view, as you can see in the following diagram: One of the main parts of the Swiss PDP Approach ® is about getting to know yourself, and I believe this is a vital step for any author looking to write a book, whether fiction or nonfiction. The following image shows you the three steps of the Swiss PDP Approach ®, the objective of each step, and who should support you: How did writing your book in Evernote affect your writing process?How do you write a book nowadays? How do you manage the vast amount of resources, literature, ideas, chapters, etc.? I can truly see the difference in the writing process between my first book, published 12 years ago, and my current one: Evernote. Evernote has been a game changer for me - it’s saved me so much time. Every idea, article, book, video, and audio recording is kept in Evernote and synchronized across all my devices. Having everything in one place allowed me to write whenever and wherever I wanted, whether it be commuting on the train, waiting at the airport, or during a flight.As the biggest challenge I faced while writing was finding the time, Evernote helped me jump a huge hurdle. I have a full-time job, I have a family, and I am a part-time EMBA professor at various universities. Finding the time to write was not easy, but thanks to Evernote, I could write during every opportunity I had: no matte r where or when, my book draft was always with me. My  biggest writing challenge was finding time. Evernote let  me write whenever/wherever I wanted. How did using Reedsy impact your book?When I was contacted by Reedsy  about a potential partnership, I first wanted to get to know the product better. As I was in the process of writing my second book, I started by using the Reedsy Book Editor to finish writing my manuscript. I took a liking to its  simple user interface and its marketplace for finding professional editors and designers.As my book is a practitioner’s book, I needed editors who could not only check for grammar and spelling errors, but also make sure that the book was clear and easy to understand. Being a non-native English speaker, it was important for me to not work with an editor who would simply rewrite everything. Yes, a native English speaker might formulate a sentence differently than me, but so what?  I wanted the book to be authentic and to sound like me. I stand for 100% quality and it is important to me that I write the books myself. Finding editors who ensured quality while maintaining my voice as an author was a great experience. I may be a non-native English speaker, but I still wanted the book to sound like me. I believe that everyone should do a PDP from time to time. If not, you run the risk of always going with the flow and being influenced or distracted by what is currently â€Å"cool.† Becoming the CEO of your own life requires you to invest time, and to engage in deep thinking and self-reflection. Try to enjoy the process, and remember that when it comes to your personal development, the results are in your hands! Becoming the CEO of your own life requires time,  deep thinking and self-reflection.

Sign language Essay Example | Topics and Well Written Essays - 1500 words

Sign language - Essay Example Sometimes, sign is confused with the practice of pantomime, but sign language does not include its environment. This paper aims to review sign language in general. Firstly, the nature of signs will be described. Secondly, the similarities and differences between sign and spoken language will be presented. Finally, a conclusion shall synthesize the main points of the paper. Sign takes place in 3-D space also known as "signing space," which is usually close to the trunk of the body and the head. Signs can be wither one or two-handed. When only one-handed a dominant hand performs the sign, and in two-handed signing, the non-dominant hand comes into play. It has only lately been realized that the non-manual forms of sign are able to effectively express the feelings of the signer (Weaver and Pentland 1). This is similar to verbal speaker's ability to transmit meaning through non-verbal means. However, for signers, non-manual channels are also critical to communicate the grammar of the language. Unfortunately, not much is known as yet about non-manual forms as compared to manual forms, however current research interests into this topic may change this. It is not unusual for a child to learn sign from... Studies have implicated many equivalent learning processes between sign and spoken language learning. Primarily for sign, inflection is of more importance than word positioning. Using a visual-gestic mode for the arrangement of inflexion, sign is very similar to Navajo or Latin language. The hand configuration used in signs means that each sign has numerous parts consisting of; the configuration, place of articulation, orientation, path of movement and non-sign components that include facial expressions (Braem 1). Some sign languages have up to 18-19 handshapes, 24 movements and 12 locations. Visual and kinetic aspects of sign make it difficult or can make it impossible for a person from learning the language from a book, such as its movement aspects. As such, a teacher is required who is more proficient in the language. Hence, a model is required to be observed by the learner, and as it is some of the best teachers are those who originated this language, that is the "deaf and dumb" (Braem 4). There are many common linguistical features to sign languages; these include the extensive use of classifiers, a high level of use of inflection and a topic-comment syntax. Mostly, the linguistical characteristics of sign language are its ability to produce meaning in different areas of the visual field simultaneously. That is, the receiver of the communication may be able to read the meaning of the signs that the hands make, whilst reading the facial expression and the positioning of the body. This is in stark contrast to oral languages, wherein sounds that make up words tend to spoken sequentially, although the use of tone takes exception to this.The body and facial expressions are essential to communication in sign. The

Processes and Evaluation in Employment Relations Essay

Processes and Evaluation in Employment Relations - Essay Example A study of the Australian workplace scenario shows that strategic HRM are often faced with issues when trying to affect cultural changes as lack employee focus, leading to increased work related insecurities and a persistently decreasing job satisfaction (Leah, 1999). Culture, which fundamentally relates to the meaning an individual deciphers about the world around him and an understanding of the tools with which he must deal with this world, the primary objective of cultural changes within a workplace is associated with conscious and active processes aimed at developing capabilities that enable individuals to find new methods of working. It makes way for new processes, beliefs, thoughts, and measures that help to bring about organizational success. Owing to current large-scale globalisation, business strategies have become more intricate, making it necessary that workplace culture within an organisation becomes more complex in order to implement various modifications. This paper wil l study the role of HRM as regards affecting cultural changes within an organisation and will derive that implementing cultural changes is a complex and difficult process, and HR management has a limited role in affecting these changes. Human resource management can be defined collectively as comprising of â€Å"all concepts, strategies, policies and practices which organizations use to manage and develop the people who work for them† (Rudman, 2002, 3). The current function of HR is to manage long-term goals, and to take a wider and more balanced approach, instead of convening only on internal issues pertaining to human resource management. Modern HR managers emphasise more on future-based goals, long-term strategies, value adding leadership roles with focus on global integration, primarily in terms of economic and socio-cultural integration (Adler and Gundersen, 2008, pp.7-9). Fig 1: Human resource activities of a modern business firm (International HRM and organizational be havior learning guide, 2010). Ulrich (1996) delineated HRM roles and divided them into four categories based on their functions. These are Change Agent, Strategic Business Partner, Administration, and Employee Champions (Ulrich, 1996, pp. 19-20). Besides these, HR managers must be knowledgeable about the socio-cultural effects of globalization and be technologically oriented. In context of HR functions as a change agent and a strategic business partner, which encompass bringing in strategic cultural changes within an organization, these are associated with guiding and assisting in creating an overall business strategy and framing of HR plans and activities, keeping in mind the current globalization. If human resource strategies are incorrectly planned and implemented, an organization is likely to face failure within the global market that is highly competitive in nature (Belcourt and McBey, 2010). Here, the human resource managers help to formulate overall business strategies and se t goals for a firm, while bringing in suitable workplace cultural changes within an organization that would assist in achieving success in overall business outcome. The word ‘organisational culture,’ which became popular during the 1980s, is often considered

Social dance Essay Example for Free

Social dance Essay Dance does not leave behind clearly identifiable physical artifacts such as stone tools, hunting implements or cave paintings. It is not possible to say when dance became part of human culture. Dance has certainly been an important part of ceremony, rituals, celebrations and entertainment since before the birth of the earliest human civilizations. Archeology delivers traces of dance from prehistoric times such as the 9,000 year old Rock Shelters of Bhimbetka paintings in India and Egyptian tomb paintings depicting dancing figures from circa 3300 BC. One of the earliest structured uses of dances may have been in the performance and in the telling of myths. It was also sometimes used to show feelings for one of the opposite gender. It is also linked to the origin of love making. Before the production of written languages, dance was one of the methods of passing these stories down from generation to generation. [2] Another early use of dance may have been as a precursor to ecstatic trance states in healing rituals. Dance is still used for this purpose by many cultures from the Brazilian rainforest to the Kalahari Desert. [3] Sri Lankan dances goes back to the mythological times of aboriginal yingyang twins and yakkas (devils). According to a Sinhalese legend, Kandyan dances originate, 250 years ago, from a magic ritual that broke the spell on a bewitched king. Many contemporary dance forms can be traced back to historical, traditional, ceremonial, and ethnic dance. Partner Dancing in Art Dance at Bougival by Pierre-Auguste Renoir (1882–83) Eadweard Muybridges phenakistoscope A Couple Waltzing (c. 1893) Dance classification and genres. Main articles: List of basic dance topics and List of dances Dance categories by number of interacting dancers are mainly solo dance, partner dance and group dance. Dance is performed for various purposes like ceremonial dance, erotic dance, performance dance, social dance etc. Dancing and music See also: Category:Music genres Many early forms of music and dance were created and performed together. This paired development has continued through the ages with dance/music forms such as: jig, waltz, tango, disco, salsa, electronica and hip-hop. Some musical genres also have a parallel dance form such as baroque music and baroque dance whereas others developed separately: classical music and classical ballet. Although dance is often accompanied by music, it can also be presented independently or provide its own accompaniment (tap dance). Dance presented with music may or may not be performed in time to the music depending on the style of dance. Dance performed without music is said to be danced to its own rhythm. Ballroom dancing is an art although it may incorporates many fitness components using an artistic state of mind. Saman Dance from Gayo people of Sumatra, Indonesia Morris dancing in the grounds of Wells Cathedral, Wells, England An amateur dancesport competition at MIT Professional dancers at the Tropicana Club, Havana, Cuba, in 2008 Dance studies and techniques See also: Dance theory, Choreography, and Dance moves In the early 1920s, dance studies (dance practice, critical theory, Musical analysis and history) began to be considered an academic discipline. Today these studies are an integral part of many universities arts and humanities programs. By the late 20th century the recognition of practical knowledge as equal to academic knowledge lead to the emergence of practice research and practice as research. A large range of dance courses are available including: Professional practice: performance and technical skills Practice research: choreography and performance Ethnochoreology, encompassing the dance-related aspects of anthropology, cultural studies, gender studies, area studies, postcolonial theory, ethnography, etc. Dance therapy or dance-movement therapy. Dance and technology: new media and performance technologies. Laban Movement Analysis and somatic studies Academic degrees are available from BA (Hons) to PhD and other postdoctoral fellowships, with some dance scholars taking up their studies as mature students after a professional dance career. Dance competitions A dance competition is an organized event in which contestants perform dances before a judge or judges for awards and, in some cases, monetary prizes. There are several major types of dance competitions, distinguished primarily by the style or styles of dances performed. Major types of dance competitions include: Competitive dance, in which a variety of theater dance styles—such as acro, ballet, jazz, hip-hop, lyrical, and tap—are permitted. Open competitions, which permit a wide variety of dance styles. A popular example of this is the TV program So You Think You Can Dance. Dancesport, which is focused exclusively on ballroom and latin dance. Popular examples of this are TV programs Dancing with the Stars and Strictly Come Dancing. Single-style competitions, such as highland dance, dance team, and Irish dance, which only permit a single dance style. Today, there are various dances and dance show competitions on Television and the Internet. Dance occupations There are different careers connected with dancing: Dancer, dance teacher, dance sport coach, dance therapist and choreographer. Dancer Dance training differs depending on the dance form. There are university programs and schools associated with professional dance companies for specialised training in classical dance (e. g.Ballet) and modern dance. There are also smaller, privately owned dance studios where students may train in a variety of dance forms including competitive dance forms (e. g. Latin dance, ballroom dance, etc. ) as well as ethnic/traditional dance forms. Professional dancers are usually employed on contract or for particular performances/productions. The professional life of a dancer is generally one of constantly changing work situations, strong competition pressure and low pay. Professional dancers often need to supplement their income, either in dance related roles (e.g. , dance teaching, dance sport coaches, yoga) or Pilates instruction to achieve financial stability. In the U. S. many professional dancers are members of unions such as the American Guild of Musical Artists, the Screen Actors Guild and Actors Equity Association. The unions help determine working conditions and minimum salaries for their members. Dance teachers Dance teacher and operators of dance schools rely on reputation and marketing. For dance forms without an association structure such as Salsa or Tango Argentino they may not have formal training. Most dance teachers are self employed. Dancesport coaches Dancesport coaches are tournament dancers or former dancesports people, and may be recognised by a dance sport federation. Choreographer Choreographers are generally university trained and are typically employed for particular projects or, more rarely may work on contract as the resident choreographer for a specific dance company. A choreographic work is protected intellectual property. Dancers may undertake their own choreography.

Meningitis Essay examples -- Health, Diseases

In nineteenth century Geneva, a family came down with a strange disease— one that had never previously been diagnosed. In a short time, many people in their town were infected and thirty-three people were left dead. This strange disease was later determined to be meningitis. In 1806, the United States saw its first outbreak of meningitis in Massachusetts. It was not until 1887, however, that Professor Anton Weichselbaum was able to determine a cause of meningitis: a bacterium called Neisseria meningitides. Penicillin was first used to combat meningitis in 1944, and in 1978, a vaccine became available. The usage of vaccines was detrimental in the battle to gain control over the spread of meningitis (7). Even with these vaccines, however, meningitis continues to infect individuals today. Meningitis is the swelling of the meninges that surround the central nervous system. The tri-layered membrane is composed of the dura mater, arachnoid mater, and pia mater, which protect the brain and spinal cord. Meningitis is contagious to other people. It can be spread through exchange of saliva, as well as from coughing and sneezing (4). Everyone is at risk for catching meningitis—even people in good health. It is especially common in young people living in close proximity to each other, such as in college dorms (6). Meningitis can be caused by several things. The more common causes include bacteria, viruses, and fungus. Other, less common causes of meningitis can be cancer, brain surgery, drugs, and chemicals (3). Bacterial meningitis is the most severe form and one must seek medical attention immediately (8). Bacterial meningitis is capable of killing a person in just one day (6). At least thirteen strains of such bacteria exist (15). The ... ... causes swelling of the meninges surrounding the spinal cord and the brain. Meningitis can be caused by several things- the most common are bacteria, viruses, and fungus. Symptoms are comparable to that of the flu; therefore people may not initially realize that they have this disease. The earlier a person seeks treatment, the better the outcome. Most people survive their battle again meningitis, but some come away with lasting affects. Meningitis has been around for hundreds of years, and in that time period, there have been many advances made in the handling of the disease. With the invention of modern vaccines, meningitis is under better control and the occurrences of infection are much lower than they were in the past. With continuing research, there is still hope to make more gains in the prevention and treatment of meningitis and potentially save more lives.

A Good Friday Celebration Essay

In many countries of the world that celebrate Easter, we think of dressing in our best clothes and going to church to pass our respects to Christ. If not Catholic or Christian, we think of a nice peaceful day with bunnies, Easter Egg Hunts for the kids, and a nice day to barbeque with family and friends. Meanwhile, on the other side of the world in a small country made up of thousands of islands is Philippines, a country that contains a majority of uneducated religious people, mostly Catholics and Christians, whom celebrate Easter in a much more traditional sense: through crucifixion re-enactments. This annual celebration of the death of Christ merges traditions of the Catholic Church with Filipino folk superstitions. So why do Filipinos go against the church wishes to emulate the crucifixion when religion is clearly a major role in their lives? Many of the people participate for penance, others as a sign of sacrifice for their prayers to God, some to honor their vow they made to the mselves and God, and others just for the experience whilst the church objects and cry out in objections of corporal punishment. Unfortunately for the church, tradition trumps the advice of the bishop and church leaders annually. Months before the scheduled re-enactments of the crucifixion begins, many of the participants will start forging their own three-inch, stainless steel nails (as seen from the photo on the on the bottom left, above, taken in 2011). The nails appear to frame the man’s face whose eyes looked glazed over and his overall appearance to be burdened with years of suffering. The points of the nails show the sharpness of the object, exposing the man’s tolerance for physical discomfort. The photo taken by Erik de Castro, captured the devotion and the man’s grub work for his chance to show his God his faith through his own crucifixion during Good Friday. In the early morning of Good Friday, thousands of people in the Philippines get ready for the celebration by first attending church then going home to cook a feast while a few hundred people start to get ready for the parade before the crucifixion. During this time, many local and foreign tourists start lining the streets, making the religious ritual into more of a gimmick, which seems to raise tourism. At around mid-day, the participants start their journey through the towns and cities to the crucifixion site. Participants will wear white and will whip their backs (as seen in the photo on the right) for every sin they have performed throughout the year. These worshipers will not only whip themselves with bamboo and rope but wear crowns of thorns on their heads—made of barbwire, as shown in the photo below– and walk barefoot to the sacred ground where the crucifixion portrayals come alive. The photo above shows the beauty of unison through the color of pants and the contrast of the blood, the symmetrical lines the men are in, and the whips going back and forth during the infliction of pain for sins. If you look closer, one man’s back is not nearly as bloody as the rest rendering us to question if he doesnâ €™t have as many sins or if he is trying to cheat pain and scarring by not whipping himself with as much force as the others. In the course of an interview with a twenty-sixth year veteran of the ritual, Arturo Bating, a faith leader in his community, has stated that he does the annual ritual because it was â€Å"a vow [he] had made to God so that He will spare [his] family from sickness.† While another twenty-sixth year veteran, Ruben Enaje, stated that he started engaging in the crucifixion ceremony because he believes that God was watching over him when he survived after falling from a building during work. Countless other devotees participate for reasons of atoning for sins or to â€Å"pray for the sick or a better life or give thanks for what they believe were miracles.† From these veterans, we can understand how these folk superstitions ties in with the traditions of the Catholic Church. But why does the Catholic Church object to a tradition of crucifixion re-enactments? Some like Amparo Santos, meanwhile, believe: â€Å"It was not my will, it was God’s will†¦Ã¢â‚¬  and cla iming â€Å"to have received ‘divine messages’ while hanging on the cross.† But many church leaders are unconvinced; which is somewhat ironic for them being men of the Church and where belief and faith in the divine supernatural is part of their job description. Church leaders like Bishop Pablo Virgilio David of Pampanga encourage the meditation of Christ’s death rather than the â€Å"self-flagellation and crucifixions† expatiating that the practices â€Å"are an imperfect imitation with doubtful theological and social significance.† Bishop David also states that â€Å"most of those who get themselves crucified or those who hurt themselves are the ‘un-churched.’† In other words, the Bishop is saying that the people who are most likely to participate in emulating crucifixions are the baptized Catholic people who hardly attend church services, which seem to be an unfair way to perceive the Catholic devotees. In final consideration, nearing the end of the parade and coming to the crucifixion site, a multitude of on-lookers gasp and hold their breaths while they admire the participants go through the agonizing torture of nails through their palms and feet while wearing a crown of thorns. What we can take away from the two photos above, is that women, although quite uncommon, can too be seen participating in the traditional crucifixion. The photo on the left shows more of how the Filipino tradition is becoming more gimmicky to attract tourists by the helpers dressed in costumes as Roman soldiers, while the image on the right, shows more of the traditional ritual, where people come together to help crucify the people wanting the experience or doing it for a reason entirely their own. While church leaders continue to object, we can see that tradition will outrival the advice of the Church to end crucifixion re-enactments. Works Cited AFP. Filipino fanatics re-enact crucifixion for Good Friday. 6 April 2012. 15 January 2013 . Bernardino Balabo, Julian Labores and D’jay Lazaro. Tradition Trumps Church Teachings. 4 April 2011. 14 January 2013 . Press, Associated. â€Å"17 crucified in Philippines in Good Friday re-enactment.† 6 April 2012. Chicago Sun-Times. 15 January 2013 . Press, Assoicated. â€Å"Philippine Worshippers Endure Crucifixion for Good Friday.† 21 March 2008. Fox News. 14 January 2013 .

Land Law – Proprietary Estoppel

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

Second Battle of El Alamein in World War II

Second Battle of El Alamein in World War II The Second Battle of El Alamein was fought from October 23, 1942 to November 5, 1942 during World War II (1939-1945) and was the turning point of the campaign in the Western Desert. Having been driven east by Axis forces in 1942, the British had established a strong defensive line at El Alamein, Egypt. Recovering and reinforcing, new leadership on the British side commenced planning an offensive to regain the initiative. Launched in October, the Second Battle of El Alamein saw British forces grind through the enemy defenses before shattering the Italo-German lines. Short on supplies and fuel, Axis forces were compelled to retreat back into Libya. The victory ended the threat to the Suez Canal and provided a significant boost to Allied morale. Background In the wake of its victory at the Battle of Gazala (May-June, 1942), Field Marshal Erwin Rommels Panzer Army Africa pressed British forces back across North Africa. Retreating to within 50 miles of Alexandria, General Claude Auchinleck was able to stop the Italo-German offensive at El Alamein in July. A strong position, the El Alamein line ran 40 miles from the coast to the impassable Quattara Depression. While both sides paused to rebuild their forces, Prime Minister Winston Churchill arrived in Cairo and decided to make command changes. New Leadership Auchinleck was replaced as Commander-in-Chief Middle East by General Sir Harold Alexander, while the 8th Army was given to Lieutenant General William Gott. Before he could take command, Gott was killed when the Luftwaffe shot down his transport. As a result, command of the 8th Army was assigned to Lieutenant General Bernard Montgomery. Moving forward, Rommel attacked Montgomerys lines at the Battle of Alam Halfa (August 30-September 5) but was repulsed. Choosing to take a defensive stance, Rommel fortified his position and placed over 500,000 mines, many of which were anti-tank types. Field Marshal Harold Alexander. Armies Commanders British Commonwealth General Sir Harold AlexanderLieutenant General Bernard Montgomery220,00 men1,029 tanks750 aircraft900 field guns1,401 anti-tank guns Axis Powers Field Marshal Erwin RommelLieutenant General Georg Stumme116,000 men547 tanks675 aircraft496 anti-tank guns Monty's Plan Due to the depth of Rommels defenses, Montgomery carefully planned his assault. The new offensive called for infantry to advance across the minefields (Operation Lightfoot) which would allow engineers to open two routes through for the armor. After clearing the mines, the armor would reform while the infantry defeated the initial Axis defenses. Across the lines, Rommels men were suffering from a severe lack of supplies and fuel. With the bulk of German war materials going to the Eastern Front, Rommel was forced to rely on captured Allied supplies. His health failing, Rommel took leave to Germany in September. General Erwin Rommel in North Africa, 1941. Photograph Courtesy of the National Archives Records Administration A Slow Start On the night of October 23, 1942, Montgomery began a heavy 5-hour bombardment of the Axis lines. Behind this, 4 infantry divisions from XXX Corps advanced over the mines (the men did not weigh enough to trip the anti-tank mines) with the engineers working behind them. By 2:00 AM the armored advance began, however progress was slow and traffic jams developed. The assault was supported by diversionary attacks to the south. As dawn approached, the German defense was hampered by the loss of Rommels temporary replacement, Lieutenant General Georg Stumme, who died of a heart attack. German Counterattacks Taking control of the situation, Major-General Ritter von Thoma coordinated counterattacks against the advancing British infantry. Though their advance was bogged down, the British defeated these assaults and the first major tank engagement of the battle was fought. Having opened a six mile wide and five mile deep inroad into Rommels position, Montgomery began shifting forces north to inject life into the offensive. Over the next week, the bulk of the fighting occurred in the north near a kidney-shaped depression and Tel el Eisa. Returning, Rommel found his army stretched with only three days of fuel remaining. Axis Fuel Shortages Moving divisions up from the south, Rommel quickly found that they lacked the fuel to withdraw, leaving them exposed in the open. On October 26, this situation worsened when Allied aircraft sank a German tanker near Tobruk. Despite Rommels hardships, Montgomery continued to have difficulty breaking through as Axis anti-tank guns mounted a stubborn defense. Two days later, Australian troops advanced northwest of Tel el Eisa towards Thompsons Post in an attempt to break through near the coast road. On the night of October 30, they succeeded in reaching road and repelled numerous enemy counterattacks. British infantry attack at El Alamein, October 24, 1942. Public Domain Rommel Retreats: After assaulting the Australians again with no success on November 1, Rommel began to concede that the battle was lost and began planning a retreat 50 miles west to Fuka. At 1:00 AM on November 2, Montgomery launched Operation Supercharge with the goal of forcing the battle into the open and reaching Tel el Aqqaqir. Attacking behind an intense artillery barrage, the 2nd New Zealand Division and the 1st Armored Division met stiff resistance, but forced Rommel to commit his armored reserves. In the resulting tank battle, the Axis lost over 100 tanks. His situation hopeless, Rommel contacted Hitler and asked for permission to withdraw. This was promptly denied and Rommel informed von Thoma that they were to stand fast. In assessing his armored divisions, Rommel found that fewer than 50 tanks remained. These were soon destroyed by British attacks. As Montgomery continued to attack, entire Axis units were overrun and destroyed opening a 12-mile hole in Rommels line. Left with no choice, Rommel ordered his remaining men to begin retreating west. On November 4, Montgomery launched his final assaults with the 1st, 7th, and 10th Armored Divisions clearing the Axis lines and reaching open desert. Lacking sufficient transportation, Rommel was forced to abandon many of his Italian infantry divisions. As a result, four Italian divisions effectively ceased to exist. Aftermath The Second Battle of El Alamein cost Rommel around 2,349 killed, 5,486 wounded, and 30,121 captured. In addition, his armored units effectively ceased to exist as a fighting force. For Montgomery, the fighting resulted in 2,350 killed, 8,950 wounded, and 2,260 missing, as well as around 200 tanks permanently lost. A grinding battle that was similar to many fought during World War I, the Second Battle of El Alamein turned the tide in North Africa in favor of the Allies. Pushing west, Montgomery drove Rommel back to El Agheila in Libya. Pausing to rest and rebuild his supply lines, he continued to attack in mid-December and pressed the German commander into retreating again. Joined in North Africa by American troops, who had landed in Algeria and Morocco, Allied forces succeeded in evicting the Axis from North Africa on May 13, 1943 (Map).

Austria Essays - Habsburg Bohemia, States Of Austria, Free Essays

Austria Austria, a small country in Central Europe famous for its gorgeous mountain scenery. The towering Alps, and the foothills stretch across the western, southern and central parts of the country. Broad green valleys, lovely mirror lakes and thick forest cover a good portion of the land. Austria with no coastline shares its surrounded borders with Liechtenstein and Switzerland to the west; Germany and the Czech Republic to the north; Hungary and Slovakia to the east; and to the south Italy and Slovenia. North-East is Vienna, Austria's capital and largest city, where about a fifth of the people live. Population Austria has a population of about 7" million. Most Austrian's choose to live in the lower east areas of the country and just south of the Danube River. Also the capital and largest city, more than one and a half-million of the Austrian population lives in Vienna. Other cities with more than 100,000 people living in them consist of Graz, Innsbruck, Linz, and Scuzburg. Culture Austrians do not like being classified as Germans, Austria is basically Germanic in language and ethnic association. Some minorities include 40,000 Croats, 70,000 Solvenes, and a small group of Hungarians (11,000) and Czechs (5,000). Most Austrian's live south of the Danube River. Austrians enjoy an array of fine foods such as a Viennese Clich otherwise known as a Wiener Schnitzel, and many fine cakes and pastries. The average life expectancy for males is 72 and females 78. Traditions In May and June Vienna hosts the Vienna Festival. This festival is a celebration of music, arts, and theater. Austrians have a great love for music, many of the greatest composers were born and played there, many like Beethoven and other popular composers. Operas are also very popular, and The Vienna State Opera House is the most popular for such an activity. Festivals play an important part of Austria. One festival takes place throughout the province of Tyrol, in the beginning of spring. People dress up and pretend to chase the evil spirits of winter away. Way of Life Most Austrians living in the cities live in four and five story apartments. Others live in single story homes, or high rises. Clothing is very much like the style here in the U.S. but Austrians tend to dress up more often. On special occasions Austrian's dress in the national dress, a green trimmed, gray wool suit with a coat and knickers for men, the women's dress consists of a dirndl; a peasant coat, a blouse, a wide Girdle, and a bright full apron. Austrians eat elegant foods and many exquisite desserts. Beer or wine is usually served with meals. Austrians love the outdoors, and the many different physical features of Austria allow the people to enjoy many different types of sports. In winter Austrians enjoy ice skating, skiing, tobogganing, bobsledding, ice hockey, ski jumping, and curling, a game in which the players slide heavy stones along the ice toward a circular target. Summer sports include boating, fishing, hiking, mountain climbing, swimming, and water skiing. The people also enjoy biking, camping, picnics, and soccer. Vegetation and Animal Life Deciduous trees, including beech, birch, and oak, are very populated in the lower altitudes. In Alpine areas conifers extend all over. Bare rocks and grass slops continue to the snow line. The boar, bear, wolf, and lynx have disappeared, but red deer, chamois, marmot, and grouse still live in the protected Alpine reserves. In the grassy flats gray goose, white tailed, and spotted eagles, and great white herons breed. In the village of Rust, white storks return annually to their chimney nests. History Around 400 B.C. Celtic tribes occupied Austria. Around 15 B.C. Rome took control from the Celtic tribes. After the collapse of the Roman Empire many different empires took control of Austria. In 955 the king of Germany, Otto I, took control of Austria, this empire later came to be know as the Holy Roman Empire. In 1806 the empire ended. The Babenberg family controlled north-eastern Austria from 976 until 1246, when the last Bebenberg duke died without an heir and the king of Bohemia seized the region. The Hapsburgs lost the Holy Roman crown in the 1300's, but a Habsburg was once again elected emperor in 1438. From

Television Plug-In Drug Assignment Example | Topics and Well Written Essays - 500 words

Television Plug-In Drug - Assignment Example Ms. Winn emphasized the points in her essay through emotional appeal on some of the aspects such as deteriorating family relationships since even during meal times the television is switched on. Ms. Winn stated that parents have settled for the convenient lifestyle provided by the television, it gives the children company throughout and therefore also acts as a babysitter. What I found lacking in Ms. Winn’s work was significant empirical evidence that would substantiate her work. Mostly she has used an emotional appeal to sway the readers off the importance of evidence that would justify her stance. Therefore, in order to get a clearer picture of the issue I looked for some empirical evidence on the topic which I researched the topic â€Å"Research on Television Addiction† on EBSCO host and found in the article â€Å"Measuring Television Addiction† by Cary W. Horvath. The article was published in the Journal of Broadcasting & Electronic Media, which I believe is a very authentic source of information, moreover the author Ms. Horvath is Assistant Professor in the Department of Communication and Theater at Youngstown State University, which for me adds a lot more value to the credibility of the research. Ms.