Wednesday, August 26, 2020
Ella Baker :: essays research papers
Ella Baker Ella Josephine Baker was conceived in Virginia, and at seven years old Ella Baker moved with her family to Littleton, South Carolina, where they chose her grandparent's farmland her grandparents had functioned as slaves. Ella Baker's initial life was saturated with Southern dark culture. Her most distinctive beloved recollections were of the solid customs of self improvement, common collaboration, and sharing of financial assets that enveloped her whole network. Since there was no neighborhood optional school, in 1918, when Ella was fifteen years of age, her folks sent her to Shaw life experience school in Raleigh, the secondary school institute of Shaw University. Ella exceeded expectations scholastically at Shaw, graduating as valedictorian of her school class from Shaw University in Raleigh in 1927. After her graduation from Shaw University, Baker moved to New York City just before the Great Depression, resolved to discover an outlet for her scholarly interest and developing sympathy for social equity. She was profoundly moved by the horrendous conditions she saw in the city of Harlem during the 1930s; scenes of neediness, yearning, and franticness. The primary political association she joined in the wake of moving to Harlem was the Young Negroes Cooperative League (YNCL), established by essayist George Schuyler in December 1930. The communicated motivation behind the gathering was to increase monetary force through shopper participation. The YNCL was headquartered in New York City. In 1931 Baker was chosen for fill in as the gathering's first national chief. Another significant experience that assisted with forming Baker's advancing political cognizance during the Depression was her work with the Workers Education Project (WEP) of the Works Progress Administration (WPA), a program intended to outfit laborers with fundamental proficiency abilities and to instruct them about subjects of worry to individuals from the work power. During the 1930s, Baker additionally started to wrestle with the issue of ladies' fairness and her own way of life as an African-American lady. She bolstered and worked with different ladies' gatherings, f or example, the Women's Day Workers and Industrial League, an association for local laborers; the Harlem Housewives Cooperative; and the Harlem YWCA. Cook wouldn't be consigned to a different "woman's sphere," either by and by or strategically. She regularly took an interest, without reservation, in gatherings where she was the main lady present, and a large number of her nearest political partners throughout the years were men. So also, in her own life Baker would not agree to winning accepted practices about ladies' place or ladies' conduct. Ella Baker :: papers research papers Ella Baker Ella Josephine Baker was conceived in Virginia, and at seven years old Ella Baker moved with her family to Littleton, South Carolina, where they chose her grandparent's farmland her grandparents had filled in as slaves. Ella Baker's initial life was saturated with Southern dark culture. Her most striking beloved recollections were of the solid conventions of self improvement, common collaboration, and sharing of monetary assets that included her whole network. Since there was no nearby optional school, in 1918, when Ella was fifteen years of age, her folks sent her to Shaw all inclusive school in Raleigh, the secondary school institute of Shaw University. Ella exceeded expectations scholastically at Shaw, graduating as valedictorian of her school class from Shaw University in Raleigh in 1927. After her graduation from Shaw University, Baker moved to New York City just before the Great Depression, resolved to discover an outlet for her scholarly interest and developing empathy for social equity. She was profoundly moved by the horrible conditions she saw in the city of Harlem during the 1930s; scenes of destitution, appetite, and edginess. The primary political association she joined in the wake of moving to Harlem was the Young Negroes Cooperative League (YNCL), established by author George Schuyler in December 1930. The communicated motivation behind the gathering was to increase monetary force through buyer participation. The YNCL was headquartered in New York City. In 1931 Baker was chosen for fill in as the gathering's first national chief. Another significant experience that assisted with forming Baker's developing political cognizance during the Depression was her work with the Workers Education Project (WEP) of the Works Progress Administration (WPA), a program intended to outfit laborers with essential proficiency aptitudes and to teach them about subjects of worry to individuals from the work power. During the 1930s, Baker additionally started to wrestle with the issue of ladies' correspondence and her own way of life as an African-American lady. She upheld and worked with different ladies' gatherings, for ex ample, the Women's Day Workers and Industrial League, an association for household laborers; the Harlem Housewives Cooperative; and the Harlem YWCA. Pastry specialist would not be consigned to a different "woman's sphere," either actually or strategically. She regularly took an interest, without reservation, in gatherings where she was the main lady present, and a considerable lot of her nearest political partners throughout the years were men. Additionally, in her own life Baker wouldn't agree to winning accepted practices about ladies' place or ladies' conduct.
Saturday, August 22, 2020
Juvenile Death Penalty Essay -- capital punishment, death penalty
A multi year old kid is at the pinnacle of their youthful life, learning and finding about adolescence, development, good and bad and future life objectives. Then again, a man of 25 has developed, lived long enough to have made both great and awful decisions and has just been accomplishing those life objectives they once thought of as a youngster. In a given circumstance, is it moral to hold these two age gatherings, with mindsets that are completely different, to similar norms and disciplines in the equity framework? Until Roper v. Simmons in 2005, the equity framework did only that, treat the activities of multi year old with indistinguishable outcomes from in the event that they had been submitted by a grown-up. In Roper v. Simmons the United States Supreme Court proclaimed it unlawful to condemn an adolescent younger than 18 to capital punishment. Previously, Roper v. Simmons, in Thompson v. Oklahoma it had been concluded that just those younger than 16 couldn't be considered for capital punishment. Were these choices right? On the off chance that a pre-adult can carry out such a deplorable wrongdoing as crime would it be advisable for them to not likewise be capable at that point to deal with the results? The opposite side of the contention against the adolescent capital punishment expresses that adolescents don't have indistinguishable thinking aptitudes from a grown-up and along these lines can't be held to same criminal reprehensibility. Realities will show that the United States Supreme Court was right in their choice to boycott capital punishment for every one of those younger than eighteen. Ongoing cerebrum imaging filters have demonstrated that an adolescentââ¬â¢s mind isn't completely evolved until late in youth making them be juvenile, have reduced dynamic limit and immature thinking and thinking aptitudes (Aronson, 2007); characteristics which ... ...onduct. (2011). Morals and Judicial Conduct. Manual for Judiciary Policy, 1-19. National Institute of Neurological Disorders and Stroke. (2010, August 18). Cerebrum Basics: Know Your Brain. Recovered July 2011, from National Institute of Neurological Disorders and Stroke: http://www.ninds.nih.gov/disarranges/brain_basics/know_your_brain.htm North, M. (2002). Greek Medicine: The Hippocratic Oath. Recovered July 2011, from National Institute of Health: http://www.nlm.nih.gov/hmd/greek/greek_oath.html Paus, T. (2005). Mapping Brain Maturation and Cognitive Development During Adolescence. Patterns in Cognitive Sciences, 60-68. Steinberg, L., and Scott, E. S. (2003). Less Guilty by Reason of Adolescence. American Psychologist, 1009-1018. Strater, S. D. (1994-1995). The Juvenile Death Penalty: In the Best Interests of the Child? Layola University Chicago Law Journal, 147-182.
Friday, August 14, 2020
Juneau
Juneau Juneau jo?o ´no [key], city (1990 pop. 26,751), state capital, SE Alaska, in the Alaska Panhandle; settled by gold miners 1880, inc. 1900. A port on Gastineau Channel, Juneau is a trade center for the Panhandle area, with an ice-free harbor and an airport. The state and federal governments are the major employers. Salmon and halibut fishing, mining, and tourism are also important economic activities. Joseph Juneau and a partner discovered gold nearby in 1880, and the city developed as a gold rush town. It was officially designated as capital of the Territory of Alaska in 1900 but did not function as such until the government offices were moved from Sitka in 1906. In 1959 it became state capital with the admission of Alaska to the Union. Juneau lies at the foot of two spectacular peaks, Mt. Juneau and Mt. Roberts. Douglas Island, a part of the city, lies across the channel. The huge boxlike Federal Building dominates the skyline. The Alaska Historical Library and Museum and the Al aska State Museum are in the city. In 1970 the municipal boundaries were extended, then making Juneau the largest city in area in the United States, at 3,108 sq mi (8,050 sq km). Glacier Bay National Park and Preserve (see National Parks and Monuments , table) is to the northwest. The Columbia Electronic Encyclopedia, 6th ed. Copyright © 2012, Columbia University Press. All rights reserved. See more Encyclopedia articles on: U.S. Political Geography
Sunday, May 24, 2020
Leadership Styles From The Canadian Military Journal ( Cmj...
Introduction Leadership is defined by Peter G. Northouse as ââ¬Å"a process whereby an individual influences a group of individuals to achieve a common goalâ⬠. Oneââ¬â¢s leadership style can shape a subordinateââ¬â¢s approach and place emphasis to the task or mission at hand as well as accomplishing long term objectives. The role of any leader is to provide direction and guidance to those who may fall under his/her command. The manner in which leadership is applied, especially in todayââ¬â¢s society and ever-changing geopolitical situations can vary significantly and be markedly effective or undermine the leaderââ¬â¢s ability to lead. In the readings from the Canadian Military Journal (CMJ) several examples are provided to support each authorââ¬â¢s viewpoint of leadership style and I will use these along with my own opinions and experiences to substantiate the importance of differing leadership styles as they pertain to the Canadian Armed Forces (CAF) and the Profession of Arms in the 21st century. Development In the assigned readings there three viewpoints about leadership are presented: transformational leadership; the warrior ethic; and a blending of transformational and warrior leadership. All three bring forth a number of differing opinions and perspectives on leadership and how it pertains to the CAF. Transformational Leadership: Something Old, Something New, as presented in the CMJ by Lieutenant-Colonel (LCol) Peter Bradley and Dr. Danielle Charbonneau, contains views on how
Wednesday, May 13, 2020
Facts About Quebec, Canadas Largest Province
Quebec is the largest Canadian province in area (though the territory of Nunavut is larger)à and the second largest in population, after Ontario. Quebecà is a mainly French-speaking society, and the defense of its language and culture colors all politics in the province (in French, the provinces name is spelled Quà ©bec). Location of the Province of Quebec Quebec is in eastern Canada. It is located between Ontario, James Bay and Hudson Bay on the west;à Labrador and the Gulf of St. Lawrence on the east;à between Hudson Strait and Ungava Bay on the north; and New Brunswick and the United States on the south. Its largest city, Montreal, is about 64 kilometers (40 miles) north of the U.S. border. Area of Quebec The province is 1,356,625.27 sq. km (523,795.95 sq. miles), making it the largest province by area, according to the 2016 Census. Population of Quebec As of the 2016 Census, 8,164,361 people live in Quebec.à Capital City of Quebec The capital of the province isà Quebec City. Date Quebec Entered Confederation Quebec became one of the first provinces of Canada on July 1, 1867. Government of Quebec Coalition Avenir Quà ©bec Last Quebec Provincial Election The last general election in Quebec was October 1, 2018. Premier of Quebec Philippe Couillard is the 31st premier of Quebec and the leader of the Quebec Liberal Party. Main Quebec Industries The service sector dominates the economy, though the provinces abundance of natural resources resulted in highly developed agriculture, manufacturing, energy, mining, forestry, and transportation industries.
Wednesday, May 6, 2020
Applying Lean Logistics to Scm Free Essays
Applying Lean Logistics to SCM The system of interconnected businesses used to push a product from supplier to consumer is defined as a supply chain. Supply chain management (SCM)[1] focuses on managing the supply chain in an effort to improve the quality and time it requires to manufacture a product. The marriage of lean production and supply chain management creates lean supply chain management, which provides a much leaner and more economical supply chain for the product to flow through. We will write a custom essay sample on Applying Lean Logistics to Scm or any similar topic only for you Order Now Much uncertainty about what supply chain management entails is present in todayââ¬â¢s society. Many people treat supply chain management as being synonymous with logistics, which is the management of the flow of goods from the origin to the consumers. However, supply chain management encompasses much more than the purchasing or management of goods to the consumer. Supply chain management is the combination of art and science that goes into improving the way your company finds the raw components it needs to make a product or service and deliver it to customers. The following are five basic components of SCM. [2] The concept of Supply Chain Management is based on two core ideas. The first is that practically every product that reaches an end user represents the cumulative effort of multiple organizations. These organizations are referred to collectively as the supply chain. The second idea is that while supply chains have existed for a long time, most organizations have only paid attention to what was happening within their ââ¬Å"four walls. â⬠Few businesses understood, much less managed, the entire chain of activities that ultimately delivered products to the final customer. The result was disjointed and often ineffective supply chains. Supply chain management, then, is the active management of supply chain activities to maximize customer value and achieve a sustainable competitive advantage. It represents a conscious effort by the supply chain firms to develop and run supply chains in the most effective and efficient ways possible. Supply chain activities cover everything from product development, sourcing, production, and logistics, as well as the information systems needed to coordinate these activities. Lean is how a properly designed and operated supply chain should function. A lean supply chain process has been streamlined to reduce and eliminate waste or non-value added activities to the total supply chain flow and to the products moving within the supply chain. Waste can be measured in time, inventory and unnecessary costs. Value added activities are those that contribute to efficiently placing the final product at the customer. The supply chain and the inventory contained in the chain should flow. Any activity that stops the flow should create value. Any activity that touches inventory should create value. Supply chains gain waste and non-value added activities for many reasons, both internal to the company and external. Regaining the lean supply chain may mean addressing many of the same issues that created the problems of extra and unneeded time, inventory and costs. The ideal approach is to design the perfect supply chain and fit your companyââ¬â¢s operation onto it. Supply chain management is meant to reduce excess inventory in the supply chain. A supply chain should be demand driven. It is built on the pull approach of customers pulling inventory, not with suppliers pushing inventory. Excess inventory reflects the additional time with the supply chain operation. So the perfect supply chain would be lean with removing wasteful time and inventory. A supply chain, with the pull, flows back from deliveries to the store or to the customer warehouse back through to purchase orders placed on suppliers. Anything that delays or impedes this flow must be analyzed as a potential non-value added activity. To develop a lean supply chain, firms should: understand lean is an ongoing, continuous improvement approach as compared to business process reengineering which can be viewed as a one-time change, build a multi-discipline team for the project-one that understands lean supply chain management, analyze the total supply chain process, not just the outbound part or just the inbound part, calculate the risks of the lean supply chain, rationalize the process, improve the process to drive change. Lean supply chain management is not about ââ¬Å"fixingâ⬠what someone else is doing wrong. It is about identifying and eliminating waste as measured in time, inventory and cost across the complete supply chain. This requires continuous effort and improvement. ââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬âââ¬â [1] http://en. wikipedia. org/wiki/Supply_chain_management [2] http://www. cio. com/article/40940/Supply_Chain_Management_Definition_and_Solutions How to cite Applying Lean Logistics to Scm, Essay examples
Sunday, May 3, 2020
The Most Dangerous Game Sequel free essay sample
The Most Dangerous Game Sequel Rainsford awoke after the best night sleep of his life. It wasnââ¬â¢t just the fact that the bed was one of the comfiest he had ever slept in, or the fact he was exhausted after being hunted for three days, but the enormous relief he felt by beating the general at his own game. He spent most of his morning planning in his mind a payback for the general. It wasnt revenge, but Rainsford felt that the general needed reminding that the game he was playing was wrong. However, Rainsford felt certain uneasiness at the fact he had won the hunt, what extent would the general go to now to satisfy his hunting pleasures? Would he now try even more extremes in hunting? Rainsford shuddered as he thought of the things the general may do, but tried to shrug them off as he thought of a plan to payback the general, and it needed to be good. We will write a custom essay sample on The Most Dangerous Game Sequel or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page As Rainsford sat down for breakfast, he asked Ivan to fetch the general. He felt almost sorry for Ivan, and he wondered how it must feel to be deaf-mute, to never have your own life and to always live it under someone elseââ¬â¢s control. But Rainsford did not have long to pity Ivan, as the general walked in. Rainsford studied his long, wiry black beard and his unnerving dark black eyes which showed no emotion. A night of sleeping with the dogs had proved very damaging on his appearance, as he had big black bags under his eyes and seemed even more exhausted than what was humanly possible. ââ¬Å"Thank you for coming up to breakfastâ⬠said Rainsford, trying to keep his voice blank. ââ¬Å"Thank you for inviting meâ⬠replied the general, his Russian accent thick and emotionless, his black eyes studying Rainsford unnervingly, as though he was studying a rare animal he was about to pounce on. Rainsford refused to be un-nerved by the general, as he knew that he must stand his ground in order for the general to take his proposal seriously. ââ¬Å"How was your night? â⬠Rainsford asked, trying to build up conversation. ââ¬Å"I have had better nightsâ⬠, replied the General, ââ¬Å"Now, I do not expect that you invited me up to breakfast for idle chit-chat, so what is the real reasonâ⬠. ââ¬Å"Rainsford allowed himself to take a moment to process his next sentence. ââ¬Å"I have a proposal, seeing as though I did not kill you for failing the hunt, I have a new game I was for you to partake inâ⬠. The general sat in silence, absorbing Rainsfordââ¬â¢s words, ââ¬Å"I have a feeling that I know the proposal, but please carry onâ⬠, expressing interest in Rainsfordââ¬â¢s proposal. ââ¬Å"I wish to re commence the hunt, except this time I am the cat and you are the mouseâ⬠. Rainsford leant back in his chair, surprised at himself for finally saying the proposal out loud. The General smiled, ââ¬Å"I thought youââ¬â¢d had a taste for the extreme hunting, when do we begin? â⬠As Rainsford watched the general head to the forest with his food, knife and hunting clothes, he prepared himself for the upcoming days. The hunt would be the hardest one of his career, and he wondered what he had really got himself in for. But as he prepared his plan, he knew that whatever happened, he would not lose. The general peered back round to the chateau, he smiled a smile he had not smiled in weeks. This was the excitement he had been craving, and was ready to trick Rainsford in every step he took. As he dived deeper into the forest, the general began preparing his plans for the next few days, with the intention in mind that he would not lose.
Friday, March 27, 2020
About Christianity
About Christianity Free Online Research Papers All Christian religions strive for the same goals to live their lives for God or the Holy Spirit. Over the years, members of religions have interrupted the texts differently from other members. This has caused many members to start or find new religions where the religion believes the same ways as they do. Some feel if people are true to their hearts and love all humankind, as God wants them to then it does not matter what religion they belong. Others feel God judges people by their actions not what religion they are. Christianity is the largest religion in the world. People look to God for answers, help, and to find meaning in his, or her life. Christianity is the largest religion of the world, and has followers from all over the world. Christianity started in Israel. Christianity has survived for 1800 years and today translated into many different languages (Parker T., 1996). On the Believe Jesus is the son of God, and he will forgive humankind of their sins. Jesus is the savor of all humankind and died for the sins of others to please God. In Christianity, there is only one God, and he will return to take his followers to his kingdom of heaven. Sunday is a day of resurrection, confession, and prayer. Followers of Christianity live his, or her lives by the teachings of Jesus through the New Testament, Old Testament, and the Trinity. There are many different religions associated with Christianity such as Roman Catholic, Orthodox, and Protestant. Each branch of Christianity has different rules and laws, and members engorged to follow. Christianity is made of many different religions combined into one for the same believes an d goals. Through the years of Christianity, the meaning is different in parts of the world and practiced differently by the followers. The name Christianity is the only thing that is the same. The interpretation of the words God spoke is different in every set of eyes of his followers. Of all the religions and members around the world, 33 percent are Christians (adherents, 2007). Christians believe there is one God, and he created Earth, all humankind, and wilderness. Even though Christianity is the largest religion, many people argue that the faith is full of myths and no facts to back them up. One of the biggest myths is Jesus was born by a virgin by a miracle of the Holy Spirit. Another myth is he went into the desert and fasted for 40 days with no water or food. Many believe there is no way even with the help of God anyone could survive this long. Another myth is that Jesus walked on top of water. To other religions, the Christian faith is nothing but lies and false hope. To Christians believing and hope is what will get one to heaven. While researching Christianity a local pastor took time out of his busy schedule to answer a few questions about Christianity. There were 10 questions asked to the pastor. What does Christianity mean to him personally? Answer= Christianity has given him a believe system, an organized life with meaning. God made him, and loves him for who he has become. Christianity has given him the feeling usefulness with his life, and has helped change rationality with others believes. Is Christianity more than a religion in his eyes? How or why? Answer= yes, what religion means to him: humankindââ¬â¢s attempt to connect with God. Please God and become one with the lord. What distinguishes Christianity from other religions? Answer= Jesus paid for the penalties and sins of others, to please God. Christians accept and forgive others of their sins. They believe within his, or herself without God their life has no structure. How and why would someone want to join this religion? Answer= anyone wanti ng a live change, and deciding to give themselves to God. People join the Christian faith for purpose and structure in their lives. To join all they need to be being true to themselves and live for God and the rules he has set forth. Is there a particular time of the day that members pray? How do they pray? Answer= members can pray anytime they feel the need. There is no certain time of the day that Christians must pray. Christians are suggested to pray anytime members are making a life changing decision or any major decision. When members decide to change jobs many pray to God to see them through this time. What are some of the rules that members have to follow? Answer= In the Christian religion there are no mandatory rules members must follow. Members have to believe in God with all their heart. Mathew 22: 36-39 (love the lord their God and others) sums it up the best for all Christians. Can anyone join the Christianity religion? Answer= Yes, anyone can join the Christian religio n no matter the color of skin or ethnic group he, or she belongs. People who believe in God and are willing to accept him into their hearts and souls are welcome to join. Since becoming a Christian has he been treated differently by members or friends of another religion? Answer= at first with friends that where nonreligious, and members of other religions. His parents where Roman Catholic and told him he was going to hell for joining a different religion. This made no sense to him after going to ministry school and finding out that Roman Catholics are a division of Christianity. People who are uneducated on religions treated him deferent. Is there a particular way that he would try to convince someone his religion and believes is the right way to god? Answer= Yes, sins puts them in hell, and breaks the faith between God, and themselves. Joining the Christian faith allows them a chance for forgiveness from God. Describe to people the changes that have taken place in his live since h e has given himself to God completely. Do members of his religion have the freedom to figure out what is true, and what is not? How does his religion handle question about Christianity believe? Answer= Yes, all members have the right to figure out what is right and wrong. At his church, they have discussion groups once a week to discuss Sundayââ¬â¢s services and he is always open to answer questions of members who are confused about the scripts and service. In this, church members are encouraged to discuss with one another what passage means to them personally. To him understanding what the passage means and putting it into an actual life experience from the past or today is one way members will truly understand the passage. Having open discussion is another way he sees if the way he is preaching is right for the members or if he needs to change his way of preaching or teaching the word of God. The Christian religion and Islam religion differ in many ways. Islam is the second largest religion in the world with 1.5 billion members, which is about 21 percent (adherents.com). Muslims believe as do Christian Jesus is the son of Mary, but Muslims do not believe Jesus is God. Jesus is one of Gods prophets just as Mohammed. Christians believe Jesus is a Trinity, three people in one (Legenhausen M. Dr. 2007). Muslims must pray five times a day, in Christianity there is no set number of times a day to pray. Muslims govern themselves by the laws and believes of Allah; the 10 Commandments govern Christians. Both religions agree on some believes such as the importance of family, fair treatment for all and living their lives for the King (God or Allah). One of the biggest differences between Christians and Muslims is the education of the two religions among the members. Christians state that Jesus is the son of God, while others call Jesus God. Muslims state that if Jesus is the son of God then he is a prophet just like Mohammed not God. This is one reason Muslims believe Christians are living the life of lies and false hope. Christians believe Jesus is the only way to salvation, as Muslims believe Mohammed is the only way to salvation. The one thing both religions can agree on is that in order to get salvation members must follow the laws and believes of the Holy Spirit or the all mighty one God or Allah. Both agree that the prophets are the true messengers of God and the only way to get into heaven is to follow the laws and believes set forth to them by these prophets. Hinduism is the worldââ¬â¢s oldest religion still practiced today. Hinduism believes in more than one God. In the Hindu faith, believe in continuing cycles of birth, life, death, and rebirth. The souls and spirit of every person is eternal in the eyes of Hindu followers. Kama, artha, Dharma, and Moksha are the main goals of life in Hinduism. Hinduism is different from Christianity by not being slotted into any central believe system (Das S., 2008). Hinduism is a way of life not believes of one individual. Members of the Hindu faith believe in truth, honesty, non-violence, and prayer. With the question of Christianity true or false and Mohammed being the last prophet, Hinduism could become the largest faith in the world. Hinduism strives from many different religions and faiths. Believes of Hinduism are the same as many other religions. Christians believe in being true to oneself, and Hindu followers believe that the actions of one will get them to heaven or the afterlife. Both faiths are different in so many ways but the same in other ways. In any religion there is going to be disagreements between them. The laws and rules one must follow will be different. The biggest thing all religions can agree upon is that their members live for the creator of land, water, humankind, and heaven. No matter what the religion one is born, lives life for the exceptional one, asks forgiveness of sins, and prepares for resurrection. Education will play a big part in the future to understanding religions of the world. When members become educated to the laws and believe of another religion, he, or she will see that most religions are very similar in origin. God wants his followers to be true to one ââ¬â¢s self and follow his, or her heart, treat others with respect. Many religions disobey this rule by telling members that other religions are not as superior as their religion. Believe and hope for a better life after death is the main goal of most religions. Older believes and practices changed in Christianity and so will the future. On ly time will tell if Christianity can survive the same believes and practices of the future followers. Research Papers on About ChristianityComparison: Letter from Birmingham and CritoCanaanite Influence on the Early Israelite ReligionGenetic EngineeringAnalysis Of A Cosmetics AdvertisementQuebec and CanadaThe Relationship Between Delinquency and Drug UseMind TravelThe Hockey GameThe Effects of Illegal ImmigrationPersonal Experience with Teen Pregnancy
Friday, March 6, 2020
Thermodynamics and the Cooking of a Turkey
Thermodynamics and the Cooking of a Turkey Turkeys are native to North America, called Indian fowls in some writings of the 1500s. Around 1519, ships began transporting turkeys back to Spain, thus beginning its migration to Europe. American Benjamin Franklin advocated the turkey as the national bird. The turkey became prominent in Europe in the 1800s during the holiday season, replacing the goose as the most popular Christmas bird in the latter part of the century. In 1851, Queen Victoria had a turkey in place of her standard Christmas swan. The Make-Up of a Turkey At the biochemical level, a turkey is a combination of approximately 3 parts water to one part fat and one part protein. The majority of meat comes from muscle fibers in the turkey, which are mostly proteins- notably myosin and actin. Because turkeys rarely fly but rather walk, they contain far more fat in their legs than in their breast, which results in the strong differences in texture between these sections of the bird and the difficulty in making sure that all portions of the bird are properly heated. The Science of Cooking a Turkey As you cook the turkey, muscle fibers contract until they begin to break up at around 180 F. Bonds within the molecules begin to break down, causing proteins to unravel, and the dense muscle meat to become more tender. Collagen in the bird (one of three protein fibers that attaches muscles to the bone) breaks down into softer gelatin molecules as it unwinds. The dryness of a turkey is a result of muscle proteins coagulating within the meat, which can result if it is cooked too long. Temperature Differentials Part of the problem, as described above, is that the different nature of the light and dark meat in a turkey result in different rates to reach the coagulation of the muscle proteins. If you cook it too long, the breast meat has coagulated; if you dont cook the bird long enough, the dark meat is still tough and chewy. Harold McGee, a food science writer, indicates aiming for 155 to 160 F in the breast (which concurs with the overall temperature indicated by Roger Highfield), but you want 180 degrees or above in the leg (a distinction Highfield does not address). Heating Differentials Since you ultimately want the breast and legs to be different temperatures, the question is how to successfully accomplish this. McGree presents one option, by using ice packs to keep the breast of the bird about 20 degrees lower than the legs while thawing, so that the legs get a heat start on the cooking process when theyre put in the oven. Alton Brown, of Food Networks Good Eats, once presented another way to establish different heating rates, using aluminum foil to reflect heat away from the breast, thus resulting in the legs heating faster than the breast. His current roast turkey recipe on the Food Network website does not include this step, but if you watch the related videos, it shows the steps involved in using the aluminum foil. Cooking Thermodynamics Based on thermodynamics, it is possible to make some estimations of cooking time for a turkey. Considering the following estimations, it becomes fairly straightforward: Assume the oven maintains a constant temperature throughout.Assume the thermal diffusivity is independent of temperature and time.Assume the turkey is so plump that it can be estimated as a sphere. You can then apply the principles of Carlaw Jaegers 1947 Conduction of Heat in Solids to come up with an estimate for the cooking time. The radius of the hypothetical spherical turkey falls out, resulting in a formula based solely on mass. Traditional Cooking Times Small bird - twenty minutes per pound 20 minutesLarge bird - fifteen minutes per pound 15 minutes It would appear that these traditional cooking times work well in conjunction with the thermodynamic calculations provided, which give the time as being proportional to the mass to the power of two-thirds. Panofsky Turkey Constant Pief Panofsky, former SLAC Director, derived an equation to attempt to more precisely determine the cooking time of a turkey. His problem is that he disliked the traditional suggestion of 30 minutes per pound, because the time a turkey should be cooked is not a linear equation. He used t to represent the cooking time in hours and W as the weight of the stuffed turkey, in pounds, and determined the following equation for the amount of time the turkey should be cooked at 325 degrees Fahrenheit. According to the report, the constant value 1.5 was determined empirically. Heres the equation: t W (2/3)/1.5 Particle Accelerators Create Shrink Wrap The plastic shrink wrap that turkeys (specifically Butterball turkeys) come in may also have an amazing connection to particle physics. According to Symmetry magazine, some of these forms of shrink wrap are actually created by a particle accelerator. Particle accelerators use electron beams to knock hydrogen atoms off of the polymer chains within the polyethylene plastic, making it chemically active in just the right way so that when heat is applied it shrinks around the turkey. Theres a bit more detail provided in the Symmetry article on the subject. Sources and Further Reading Thermodynamics OverviewThe Physics of Christmas by Roger HighfieldSymmetry Breaking blog - The Panofsky turkey constantPhysics Talks Turkey This ThanksgivingSymmetry magazine - Accelerator applications: shrink wrapFood Network - Good Eats Roasted Turkey recipeCocktail Party Physics blog - A Taste of Science for Turkey DaySymmetry Breaking blog - Physicists talk turkey
Wednesday, February 19, 2020
The Age of Reagan Assignment Example | Topics and Well Written Essays - 250 words
The Age of Reagan - Assignment Example hilosophy, ones experiences, ones exposure to the raw edges of human existence, ones religious training, ones attitudes toward life and family and their values, and the moral standards one establishes and seeks to observe, are all likely to influence and to colour ones thinking and conclusions about abortionâ⬠. Reagan was a president who worked against the communist agendas. As per (Vlib)ââ¬Å"Under the Reagan Doctrine, one by one, it was the Communist dominos that began to fallâ⬠. Reagan has been a lash on the violent history of communist activities and he had won cold war and even changed the face of American in many ways. By ending communism he proved to be a man who put a hold on the violent centuries of communism. As per (History Place, 1982) ââ¬Å"The President eloquently explains the reasons behind his staunch opposition to Communism while encouraging the British to aid in the worldwide struggle for freedom, recalling the success of former Prime Minister Winston Churchill in the fight against Nazi tyrannyâ⬠. Reagan has been successful in combating communism and this was a revolutionary phase in American politics. Ameircan Rhetoric, . (2001). Address to the Republican National Convention. In http://www.america nrhetoric.com. Retrieved May 18, 2014, from http://www.americanrhetoric.com/speeches/part
Tuesday, February 4, 2020
The Future Role of Nursing in Health Promotion Essay
The Future Role of Nursing in Health Promotion - Essay Example According to World Health Organization, health promotion is "the process of enabling people to increase control over, and to improve, their health..."In extension to that, Ottawa Charter for Health Promotion further illustrates health promotion by stating that in order to develop a holistic wellbeing, a person or a community is required to be capable of identifying their needs and realizing their aspirations. In addition to that, satisfying their needs and coping with the environment is also another prerequisite for suitable health wellbeing. Hence, health can be perceived as a tool assisting in a better quality of life and not a purpose of living. This concept further encompasses resources borne by individuals and society along with their physical capacities. Therefore, health promotion is a combined responsibility of society as well as individuals in order to have a long-lasting impact (Keleher, MacDougall, Murphy, 2007). Ã There are five distinct health plan actions outlined by Ottawa Charter (1986). Firstly, developing an extensive public policy is an underlying foundation for further health promotion strategies. Followed by it, developing personal skills, strengthening community actions define how individuals, as well as groups, can play their role in promoting health. Lastly, creating a supportive environment and reorienting health services provide cornerstones of further strategies required to be followed for health promotion.
Monday, January 27, 2020
The Transgender Subculture in Malaysia
The Transgender Subculture in Malaysia 1. Introduction According to a privately-sponsored survey conducted in 2001, there were estimated at least 50,000 transgender people in Malaysia. Other than that, the number of transgendered people in Kuala Lumpur alone was estimated to be 50,000 which show 200 individuals in Malaysia is transgender (Wong, 2005). The study of the transgender subculture mentioned here is an explorative inquiry into the existence and the intricacies of the subject. The objectives of this study is to provide an in-depth look into the transgender subculture usually described by the term Pondan or Mak Nyah, which is much commonly used in Malaysia. Beforehand, pondan is actually a derogatory term for shemales and trangenders, whereas the term May Nyah is from the word mak, which means mother in Malay language. Both terms is used to describe a man who wants to act or dress like woman. Due to peoples limited understanding and misconceptions, some slang is publicly used to tease transgender individuals. In fact, it may cause a lot of negative impacts on them such as decreasing their self-esteem and self-efficacy. Likewise, transgender is defined as a state of an individual gender identity not matching their actual sex which they were assigned at birth, and also takes in cross dressers and transsexuals. Cross dressers are hetero males who like to dress as women on occasion whereas transsexuals is people who are born in one gender but identify with the other. The cause of transgender ideals can be both nature and nurture factors. Biologically, the factors includes differences in how the human brain functions, neurochemical pathways, and the endocrine glands. However, the nurture factor does play an important role to active the inert gene of an individual to become transgender. Sociologist strongly believes that there are influences from cultural and environmental of the local community on transgender (Zhou, Hofman, Gooren, Swaab, 1995). Moreover, transgender had been practiced long ago before it was being identified in 19th century which is 1880s in Germany. During 1886, Richard von Krafft-Ebing which is a German doctor began studying the occurrence of gender divergence. At first, transgender was coined gynandry and later he described it as metamorphosis sexualis paranoia in 1902 which mean a homosexual that truly believed him or herself to be the different from his or her assigned sex. Furthermore, Krafft-Ebing believed that homosexuality was a mental illness and delusion (Hunnicutt, 2004). In fact, the first true pioneer that involve in the field of transgender was Dr. Magnus Hirschfeld which is a gay physician that dedicate himself to the studies on the fields of sex and gender. He was the first to coin the most two popular terms to describe transgender which is transvestism and transexualism (Melville, 2004). In addition, transvestite has become kind of archaic expression and one many transgender people take the exception to.à Transgender is the popular expression of the day. The main problem that transgender face in Malaysia is that they are unable to change his or her sex identity in their identification card after they undergo sex reassignment surgery (SRS) or gender reassignment therapy (GRT) although SRS and GRT is legal in Malaysia. This occurrence shows that government are still not being recognized nor accepted. In religion aspect, Islam strictly not recognized or accepted transgender because they do not allow males to wear womens clothing and they were normally isolated. There are a significant number of transgender individuals who have been treated unfairly simply because of their sexual orientation and gender identity. (this also check see got link or not) According to a recent survey done by National Center for Transgender Equality, fully 42 percent of gay individuals say they have experienced some form of employment discrimination at some point in their lives. However, transgender workers face even higher rates of workplace discrimination and harassment. An astonishing 90 percent of transgender individuals report experiencing some form of harassment, mistreatment, discrimination on the job, or hiding from who they are to avoid it (Burns, 2003). Moreover, activists have estimated there are at least 50,000 transgender in Malaysia, many of whom face widespread prejudice and often cannot find employment (Eileen, 2011).à According to Wong (2005), a journalist from The Malaysian Bar, reported that transgender in Malaysia is still being heavily discriminated, understated and misjudged. They face many obstacles and challenges since community of Malaysia was mired in a mindset that transgender is abnormal and should somehow be treated. There are still many bias and stereotyped toward transgender in Malaysia. One of the ways to decrease and prevent bias and stereotype is through education and help more people understand about transgender. To arrive at a deeper understanding of the transgender subculture, we would discover their social relationship such as their socialization with family, peers, education and workplace. In this study, we have collected our data using questionnaires and face-to-face interview. 2. Results/ Findings 2.1 Participant 1 She is Fazura, this is the name after she decided to become a transgender. Her original name was Faiz, she was a normal male during her high school period and there is a personal reason that she decided to become a part of the transgender. During the interview, she explained that during the age of fourteen to fifteen, one of the vital reasons that she becomes a transgender is that she was hurt so deeply by one of the female during her high school years, till the point she decided to become part of it. She was from an average family which consists of four siblings, and she had two sisters that passed away far early before she was born. After years, she found out that her mother wishes to have a daughter but sadly all of her sisters were not fortunate enough to stay longer. The issue made him to think deeply and give him the encouragement to move further into the world of transgender. Family members could not accept the fact of her being a transgender, but slowly getting used to it and being comfortable around her. And from the family background of her that we know, she is the only transgender individual in among her family and relatives. Fazura would not feel concern about how other looks at her being a transgender or planning to go overseas where people would be more open-minded on transgender. She intends to stay here with her family and overcome her problems. Furthermore, being a transgender, Fazura is being very specific on her daily diet, and will go for jogging mostly everyday to keep healthy and fit. Also, she starts to consume contraceptive pills after she decided to become a transgender when she was twenty. She has to keep this as a daily routine in order to have a feminine outlook on her body. She is also planning on a plastic surgery if her financial condition can support her to do so, but she claims that she will not undergo sex reassignment surgery (SRS) because in the later years, she might wish to become straight as a normal male again. As a minority group of the society, Fazura explained that she will only hang out in place like Sunway Pyramid shopping centre and cafà © only with her group of friends. Most of her friends were transgender and PLU (which means people like us), she felt comfortable around them other than walking alone and face conspicuous sight from the public. Sometimes she might join her friends to have a small picnic gathering in Port Dickson once awhile. And as a transgender, finding a partner is not an issue for her because once in awhile she will meet someone who is similar to her or someone who is interested with her, but keeping a relationship to last long is the difficult part. Fazura mentioned that she had six partners before and were not as faithful as seems. She further explained that in the society of transgender, partners were usually come and goes, they never last long because everyone is seeking for something new and exciting rather than staying with an individual. She sees herself as an open-minded, tolerance and patience person. As a transgender Malay, she prefers to meet a partner that is smart, high moral and can financially support her. It is because they can take her equally in every decision and will not be bias just because she is a transgender. For now, she would not concern about any relationship problem at the moment because she has to focus on her work, she need to support her family and moreover a mother who is falling ill. As a twenty six years old Malay transgender, she now works in the company of Sunway Lagoon as a marketing clerk. She has a stable financial income and a flexible lifestyle, as a transgender it does not have any major negative effect on her career. She is also a part time makeup artist for wedding couple. 2.2 Participant 2 Danny is 28 years old from Malaysia. His behaviors are feminine, fashionable, gentle, and well-mannered. He was raised in Perak and moved to Klang in order to further his study in Pengajian Islam at a local university. He stopped his study after 2 weeks because he felt uncomfortable to continue his study due to his shemale identity which is against his religion (Muslim). Currently, he is working as a makeup artist in an international makeup company in Shah Alam. From his past experiences, Danny explained that he changed himself to shemale because of the external environment he was raised and influenced. During that time, the people around him often said his appearance look like a girl. She also used to play makeup and girl thingy when he was young. This is why he wanted to transform into shemale. But, when he decided to become a shemale, his family members could not accept his decision however, as time passes his family slowly accepts who he is. At the age of 25, he decided to transform himself from shemale to gay by stop consuming hormone pills and stop dressing up like a woman. The reason why he transforms himself is because: Firstly, after his mother passed away, he does not want his brother feel embarrassed about his identity. Secondly, his company does not accept him as a shemale due to any clients which is Muslim religion will refuse or reject his makeup services to them. Besides, Danny is currently in a relationship with his partner. In fact, he actually had a thought of forming his family by adopting children and raise them. His ideal partner type must be a Chinese, handsome, and has stable income. In contrast, he never expects that his love relationship could last longer. Thus, he does not treat his relationship with every partner seriously. Additionally, he keeps his identity in a low profile whenever he goes out with his partner because he does not want to expose his identity to others. In the meantime, he enjoys hanging out with his clique that consists of gay and shemale to shopping and picnic. He takes his career seriously as a professional makeup artist whereby he does not mix his personal things with his job. However, he still had the thought of transforming back to a normal guy when he becomes old. 2.3 Participant 3 Renee James is 66 years old from Chicago, USA. He was married with a woman, and had three children and seven grandchildren. He became transgender in his 40s and came out to his wife about ten years ago. He did not tell his family about his transgender orientation, only his wife knows. This is because he thinks that it would be a burden for them to carry. He believes that most of his family, relatives and friends would accept him, but he does not want to go there. He frequently stays at home. Renees personality is somewhat introverted, quiet and shy. He will try to avoid conflict with others. Besides that, he likes to write, take long walks with his dog and canoe. He usually spends most of his time with his wife and occasionally has lunch with some transgender friends. Additionally, he has been active in the Chicago trans community ever since. He will attend two or three transgender community meetings monthly and visit with family once a week. Renee is financially secured. Currently, he is a free-lance writer and a magazine editor. His magazine career was not being affected because he never came out as transgender in his professional life. He wrote a novel Coming Out Can Be Murder as a trans woman. He had encountered many barriers to success because he is a transgender and the book is about a transsexual woman. Until now, Renee still lives in two different identities, because it is illegal to change the name. He also feels conspicuous when he presents his female persona. Although he knows that he should not be bother with what others think about him, but still, he is. After he proclaims that he is a transgender, he felt a sense of euphoria and relief. However, that does not last very long because reality sets in for most transgender, transgender is a very difficult struggle for acceptance. The most challenging and difficult part that Renee faced is acceptance. This is because many Caucasian and African male-to-female transgender dont look right. For example, they are too big, too broad-shouldered and others. Renee said that, Male-to-female transgenders in Asia have a different experience that we in the US. In some Asian countries-notably Thailand-the difference in size between men and women is not as great as in Caucasian and African gene pools, so more trans women are able to pass as women. From what Ive read, though, they are just as stigmatized as we are here in the US. Hence, it is hard even for kind people to accept them. Within a marriage, acceptance is also very difficult because his wife feels threatened by his identity. She fears he will transition to full time female, become attracted to himself, have an affair with another person, or somehow embarrass the family. At first, it was very difficult for his wife, but at last she supports him and they go on. About five years ago, Renee began taking small doses of estrogen. It doesnt affect his body because he does not take testosterone blockers. Nevertheless, the estrogen seems to soothe some of the mental conflicts he had. The result is that he had a milder disposition which he dont get mad as often, and dont get as mad as he once did. He liked both boy and girl things as a child and still today. He is comfortable in a male presentation, even though much of the time he would prefer to be a woman. He claimed that he has a mans body and a bi-gender mind. 3. Discussion There are interplay of nature and nurture in transgender. Previously mentioned, there are biological effects in transgender. James (2012) stated that transgender is not a decision they make, it is how their brain develops. In the womb, we all start out female, but our bodies and brains evolve and some of us become male. The brain, including the parts that determine gender orientation, continues to develop after birth. What can decide is what to do about that? Some who born in male dont have the same brain chemistry as other males and end up identifying as female or, in some cases, identifying as both male and female. Some decide to hide their identity, but as time goes on it become impossible (James, 2012). Moreover, in our findings, the participants become transgender due to the influence of family, peers, and society. Besides, transgender concerned about their appearance. They will exercise and diet in order to keep their body fit. They also learn how to makeup from magazine, friends and television shows. Additionally, they consumed contraceptive or birth-control pills such as Marvelon, Levora, and Camilla which contains estrogens to decrease male hormone and increase female hormone. According to Cross (2012), men may experience larger breasts, less facial hair and smaller testicles if they consume the pills. Furthermore, they are materialistic and like branded things such as Louis Vuitton, Gucci, and Prada. The major struggle for transgender is acceptance. Transgender like to seek for acceptance from society. In family viewpoint, transgender was not easily being accepted by their parents and siblings where they will tend to feel embarrass and confuse. As time flies, family would gradually accept them as who they are. Mostly relatives and peers could accept them as transgender. In societal perspective, the communities are still stereotyping transgender yet they are not easily bothered on how the communities look on them. One way or another, they are more concern on familys view than others on them. Likewise, transgender are not being accepted by most of the religion. In terms of relationship partner, our findings illustrated that transgender relationship usually would not last long. Transgender would not take their relationship seriously because their main concern for both sides is to satisfy their own sexual instincts. So, they will easily feel bored with their partner and always seek to change for another. Nonetheless, there is minority who able to marry (heterosexual) and involve in a long-lasting relationship (homosexual). In addition, transgender also hope to have their own family. According to our results, participants are financially secure and stable in their work. They tend to work professionally in their job and are not easily affected by personal matter. However, there are exceptions. Wong (2005) stated that there are approximately 80% of the transgender in Malaysia become commercial sex workers because of discrimination by prospective employers. Wong (2005) also declared that: Many are academically qualified to hold professional positions but are denied the opportunity for employment. Many end up in the sex industry as well as stereotyped professions such as hairdressing and entertainment. One must question how genuinely free the choice of being a sex worker can be if opportunities for other kinds of employment remain limited. One must also understand and acknowledge the way transsexuals have been [socialized] into seeing themselves and the insidious barriers set up by corporations and prospective employers. From our findings, transgender characteristics are open-minded, soft, tolerate, and non-aggressive. They are more introverts whereby they prefer to stay at home often. In addition to that, transgender usually go out with their clique or with someone who is close with them instead of go out alone. However, being a well-mannered citizen does not mean that they are free from the disturbance of the authorities. In one of the annual events, Seksualiti Merdeka, was being held to represent a coalition of Malaysian Non Government Organizations (NGOs) including Malaysian Bar Council, SUARAM, Empower, PT Foundation, United Nations, Amnesty International and individuals. Through the event, it has disclosed the Malaysian government was unwilling to provide equal rights to transgender and therefore transgender faced difficulties in accessing health care, education, housing, employment, and other rights that shared by Malaysian. For example, the transgender community has reported that they are bei ng discriminated on attempting to open bank account and applying passport. Moreover, 70% of the transgender reported that they are being caught by the police raids and have been treated brutally such as striped their clothes in front of others in the police station. (this also see is what link de) Overall, this study could not be generalized due to the lack of participants and the reliability of our resources. This is because our study only involved three participants. In order to generalize the study, we need a wider population. More participants should be recruited from different culture, races, ethnic and nationality. Moreover, this study was conducted in three weeks. The duration was considered short whereby there are limited time and resources for us to collect our data. More time should be provided in order to collect more dependable and valid information as well as to increase the degree of consistency and reliability of the study. Therefore, further research need to be conducted to obtain more significant and reliable results. In a nutshell, the transgender experiences vary across the region. Some area could accept transgender whereby they do not have to endure a lot of rudeness from others. In other areas, people tend to be very conservative and religiously dogmatic, where transgender individuals live secret lives. Yet, everyone deserves to be free from discrimination, violence, harassment and for their sexual orientations as well as their gender identities. Lastly, we should educate our young generation to be knowledgeable and understanding so that they would not easily discriminate, blames, and judges others without knowing the truth. References Burns, C. (2003). The costly business of discrimination: The economic costs of discrimination and the financial benefits of gay and transgender equality in the workplace. Retrieved September 29, 2012, fromà http://www.americanprogressaction.org/wp-content/uploads/issues/2012/03/pdf/lgbt_biz_discrimination.pdf Cross, C. (2012). The effect of birth control pills on male. Retrieved from eHow: http://www.ehow.com/facts_5634953_effect-birth-control-pills-males.html Ee Lynn, Wong. (2005, February 1). Neither Here Nor There: The Legal Dilemma of the Transsexual Community in Malaysia. Retrieved from The Malaysian Bar Web:à http://www.malaysianbar.org.my/gender_issues/neither_here_nor_there_the_legal_dilemma_of_the_transsexual_community_in_malaysia.html (How about this? All need big letter? The title I mean..) Eileen, Ng. (2011, July 19). Malaysian transsexual loses court bid to officially change gender despite sex-change surgery. The Associated Press. Retrieved fromà http://www.macleans.ca/article.jsp?content=w7542884 (What mean The Associated Press? Retrieved from The Associated Press: then add?) Hunnicutt, A. (2004). Krafft-Ebing, Richard von (1840-1902). Retrieved from http://www.glbtq.com/social-sciences/krafft_ebing_r.html James, R. (2012). Coming out can be murder. United States: Windy City Publishers. Melville, R. (2004). Dr. Magnus Hirschfeld. Retrieved from StoneWall Society: http://www.stonewallsociety.com/famouspeople/magnus.htm United Nations Country Team. (2011). Malaysia: The millennium development goals at 2010. Retrieved from http://www.undp.org.my/files/editor_files/files/Malaysia%20MDGs%20report%20clean%200419.pdf Zhou, J.N., Hofman, M. A., Gooren, L.J.G., Swaab, D. F. (1995). A sex difference in the human brain and its relation to transsexuality. Nature 378: 68-70.
Sunday, January 19, 2020
A Journey Through Music Essay
One warm summer evening just over a year ago, I picked out a book from my parentsââ¬â¢ bookshelf and flipped to a random page while attempting to pass time. The book, known as the Tao-te-ching, is a famous work by the ancient Chinese Philosopher Lao-Tzu written more than 2500 years ago. Because of its age, the book is written in old Chinese, which makes it very difficult to read. Interested just in passing a few minutes, however, I flipped through the pages at random, looking for anything to catch my attention. And suddenly, right in front of my eyes, I see a quote which sets my brain in motion: ââ¬Å"This journey of a thousand miles begins with a single step. â⬠In general, I do not think quotes can be long enough to be meaningful. However, looking at this quote, I feel a shiver run down my spine as I realize that these words written far back in time have a true meaning to me. For in my own lifetime, one small decision that my family made influenced my whole life, and has led me to journey many miles both physically and mentally. It was when I was four years old that I took the first step in a journey which would influence my life forever. My cousin was learning to play the piano and her parents suggested that I learn to play as well. I was enthusiastic about the idea of doing something new, although at the time I had no idea of the amount of impact this one decision would have on my life. From very early in my studies, I began to develop an emotional connection to music. While I was playing the piano, it seemed as if feelings and thoughts which had been living inside of me were suddenly being released into the outside world. I was struck by the power of music; while enjoying one of Prokofievââ¬â¢s War Sonatas, I was transported to the dark, dangerous place that was Russia during World War II, whereas while performing a work by Mozart, I was transported to a gamboling, carefree, and joyful world filled with youthful innocence and vigor. And music has had the power to bring me to many new physical places as well. Thanks to the piano I have traveled across Asia and Europe to play with various orchestras and to compete in numerous competitions. I have met and played for luminaries such as US secretary of state Hilary Clinton. And finally, piano brought me to America where I continued my studies at the Juilliard School. Funnily enough, my travels as a result of the piano made me realize the diversity that exists in the world; they made me realize how many different ideas and people all exist simultaneously. And this brought me a desire to learn as much as I can, to expand my intellectual and physical horizons, and to understand as much of the world as I can. This is what led me to the decision not just to attend a Music Conservatory, but to enter an Academic University and venture into new territory. And while I eagerly await this unknown path I am about to take, I am certain of one thing: without the tentative first step of beginning the Piano that I took when I was four, the eye-opening journey I have taken over the past thirteen years would never have begun. And I know for sure that the Piano will always remain a part of my life.
Friday, January 10, 2020
Religion in Brazil
Brazil, orà officially theà Federative Republic of Brazil is the largest country in bothà South Americaà and theà Latin Americaà region. It is the world's fifth largest country, both bygeographical areaà andà by population over 190 million people à It is the largestà Lusophone, or portugese-speaking,à country in the world, and the only one in the Americas. com/ways-religion-economics-influence-development-medieval-europe-japan/">Religion plays a major role in the lives of most of the people in this largest South American county. Here are some interesting Brazil facts: Around ninety percent of this population identifies with some sort of religion, à making it more religiously inclined than any other South American country.Only around 1% of its population do not believe in a God, or a supreme being in some form or another. The Brazilian Constitution of 1889 declared that there was noà officialà religion in Brazil, so everyone was free to believe as they like d. Thatââ¬â¢s why, just like the USA, Brazil can practice freedom of religion according to the newest constitution that was adopted in 1988. Brazilââ¬â¢s religious make-up can be traced to the diverse groups of people who came in various forms ââ¬â natives, invaders, immigrants, and slaves. In terms of Christian religions, the main churches in Brazil are: â⬠¢ Catholic Protestant â⬠¢ Methodist â⬠¢ Episcopal â⬠¢ Pentecostal â⬠¢ Lutheran â⬠¢ Baptist Its religious inclination is also extremely diverse, despite the fact that around three-quarters of the population claim to be Roman Catholics. In fact, there are more Catholics in Brazil than in any other country in the world. The Portuguese brought with them, not just the language (thisà medical tourismà hub is the onlyà countryà inSouth Americaà not dominated by Spanish), but also Roman Catholicism. Catholicism was introduced to Brazil when the European settlers arrived with the aim of ââ¬Ëc ivilisingââ¬â¢ the local native people.They built churches and brought religious leaders into the country to teach young and old alike the doctrines of Catholicism. During the 19th century, Catholicism was made the official religion of Brazil. This meant that Catholic priests were paid a salary by the government, including them in the political affairs of the country. As such, Catholicism became an integral part of the management and administration of Brazil and its people. Many of the Brazilian festivals are based on the Catholic religion. Protestantism is the second largest branch in Brazil religion.Those who are Christian but not Catholic are considered Protestant. Only about 15% of Brazilians claim to follow a Protestant faith of some kind. There are many branches of Christianity in Brazil. Among them the most popular are Baptist, Methodist, Neo-Pentecostalists, Old Pentecostalists, Presbyterian, Anglican and Episcopal Churches. Other Protestant beliefs and offshoots that mak e up smaller portions of ââ¬Å"Christiansâ⬠are Kardecist, Lutherans. The largest population of Protestants are found in North, Central-West and Southeast Brazil. The Church Of Jesus Christ of Latter-day Saintsà is the third largest Brazil religion.They boast a membership of over one million one hundred thousand with almost two thousand congregations and 309 family history centers. Five temples are stretched across Brazil. Jehovah's Witnessesà is the fourth largest religion in Brazil. They have over 700,000 members. Eastern Orthodoxà makes up the fifth largest religion in the country with over 500,000 members that came over with their Armenian, Greek, Lebanese, Russian, Syrian and Ukrainian immigrants in the past one hundred years. When the Portuguese landed in Brazil, theà countryà was populated by nativeà Indians who had their own traditional religious practices.In the regions just north of Bahia, indigenous tribes still practice the Catimbo religion; a sect that is heavily influenced by spirits, shamanism, and omens. When African slaves began to be imported into Brazil, they brought with them their religious practices, many of which involved invoking the gods through chants or dances. Over time, these Afro Brazilian religious practices began mingling with Catholic and Protestant influences to create synthetic religions. Some of the moreà popularà exponentsà includeà Candomble, which has a huge following in urban centers likeà Rio de Janeiro, and Umbanda.Spiritism is also one of the significant, although minor, religions in Brazil. Spiritistic practices are based largely on ancient Amerindian cultures as well as the influence of the African cultures and customs that were introduced centuries ago, when slaves were brought over to Brazil from the ââ¬ËDark Continentââ¬â¢ of Africa. Such tribes and cultures were particularly inclined towards the worship of spirits since they had not been influenced by more structured notions of creation, which hailed from a reliance on the teachings of Bible.The religions or belief systems found in Brazil other than the ones above include: * Muslims * Methodists * Episcopalians * Buddhists * Ayahuasca * Afro-Brazilian religions ââ¬â Xango, Batuque, Umbanda, Tambor de Mina * Hinduism * Islamists * Shinto believers * Judaists * Rastafarian * Brazil Religion Makes the Country Unique Every part of the country has been uniquely shaped by the religion practiced there. Celebrations, festivals, traditions, and customs are all practiced due to some religious or spiritual beginnings and purposes.For example, During the Holy Week before Easter, several Brazilian cities will celebrate Corpus Christi by artistically creating mosaics or carpets on the streets using mediums like flour, flower petals, shavings of wood, and coffee grounds. The results are stunning and a memorable way to celebrate this holy time of the year. The music, dancing, chanting, singing, or other activities all stem from one faith or another and make the people who they are. The entire culture of the Brazilian people is intertwined with religion or faith in some way. No wonder they're such an amazing, diverse, and wonderful people!
Thursday, January 2, 2020
Cell Phone Overuse Or Addiction - 2080 Words
Ever since it was first introduced in the year 1973, the cell phone has evolved to become the device that holds the future within itself. Now referred to as the smartphone, the majority of the developing worldââ¬â¢s population uses it now. Itââ¬â¢s endless evolving functionalities, as apps and programs, are making the users see this piece of technology as a holy grail, but only much more accessible. Ever since its integration into our society, cell phones have given us the opportunity to connect to people at every inch of the world at anytime of the day. For ourselves, cell phones, particularly smartphones, have offered us an infinite amount of information all within the span of our hands. Its abilities outmatch even some desktops and laptops, all with the benefit of being mobile. The numbers of cellphone users have skyrocketed within recent years. With the growing number of cell phone users, the issue of cell phone overuse or addiction has been a question of much concern for p sychologists, sociologists, and scholars of education. In recent studies, cell phone addiction or nomophobia, a short term coined by UK Post Office for no-mobile-phone phobiaâ⬠has been compared to other behavioral addictions such as gambling which are included in the Diagnostic and Statistical Manual. Nomophobia has not made its entrance into the Diagnostic and Statistical Manual even though it has the symptoms that parallel those that behavioral addictions have. The reason this has not been placed into theShow MoreRelatedCell Phones And Its Impact On Society892 Words à |à 4 Pagesproblem lurking beneath that shiny exterior. Cell phones have made a dramatic advancement from the bricks with antennas to the sleek touch screen that seems to occupy the hands of every teen and working adult. These smartphones act as a status symbol for whatââ¬â¢s in style as well as whoââ¬â¢s on top of the social pyramid regarding the large variety of social media that can be accessed thro ugh such a small device. The younger generations might argue that cell phones are absolutely necessary in todayââ¬â¢s societyRead MoreEssay about Student Overuse of Smartphones 767 Words à |à 4 Pagesthe devices in other unusual placesâ⬠. One of the typical examples is the overuse of a smartphone can easily get oneââ¬â¢s attention and be distracting. As a result of overuse smartphones, there is an increase in relational, educational, and health problems. As technology advances, more and more people view smartphones as something that they must have in their hand all the times. The overuse of smart phones has become an addiction. Suzanne Kane reports that a recent study found that, ââ¬Å"72% of AmericansRead MoreEffects of Modern Technology852 Words à |à 3 Pagestechnology has a negative or positive effect. Whether it is something you see on TV or in oneââ¬â¢s own everyday life, it is more popular to see someoneââ¬â¢s face focused on a phone screen rather than buried in a book. Over the past few decades, technology has been getting more popular as new developments arise. Not only are cell phones a main priority, but also computers, the internet and video games. Ever since the invention of the first programmable computer in the 1937 which was the size of an entireRead MoreCell Phone Addiction Essay1429 Words à |à 6 PagesThe cell phone has become a centerpiece of everyday life as cell phones are evolving and have been in creasing their functionalities. Today, we use them today for many others reasons than what cell phones were originally designed to do. People are using them so often that they are becoming dependent on their phones that they have even become addicted to them. Those who are addicted to their cell phones struggle to stay away from them for a certain period of time and become so indulged in all of theRead MoreThe Problem with Cell Phones in Todays Society1390 Words à |à 6 Pages11 Nov. 2014 Outline Thesis: The usage of cell phones in modern day society has caused quite the problem for citizens in this generation by being a major distraction, causing addictions, and has sadly became the main resource of communication. I. Introduction: What if every cell phone in the world crashed? How would society communicate? How would one know when someoneââ¬â¢s birthday is without getting a notification for it? Some people wouldnââ¬â¢t even know when to get up each morning. Thirty yearsRead MoreApplication Of Mobile Phones : The Mobile Phone Amusement With The Fire Phone942 Words à |à 4 Pagescellphones wasnââ¬â¢t that popular. That being said, everyone did not wait in line just to get the new Nokia phone. However, the world wasn t exactly prepared for the iPhone when it was divulged in 2007. The originator Steve Jobs dispatched the in with no reservations one advanced music player, camera (2MP!), and Internet-empowered PDA gadget, and the rest is history. Application empowered cell phones assumed control over the business sector after the arrival of the iPhone. Google s publicly releasedRead MoreTechnology And Its Effect On Society1396 Words à |à 6 Pagesadvances and its overuse are redefini ng social interaction and the cultural fabric of society. Gradually, the overuse of internet and mobile technology seems to be destroying the significance of interactions we have with others, disengaging us from the people around us and leading to a sense of isolation in todayââ¬â¢s society. A 2014 Nielsen survey found on average, Americans spend 60 hours a week consuming content across various digital devices (Nielsen). We now mostly communicate by phone calls, textingRead MoreMobile Phones : The Way We Communicate With Each Other880 Words à |à 4 PagesPhones definitely change the way we communicate with each other. We have the freedom to call or text someone whenever we want to without anyone knowing. Yet, as cell phones evolve over the years the world wasn t exactly prepared for the iPhone when it was divulged in 2007. Creator Steve Jobs dispatched the in with the new advanced music player, camera (2MP!), and Internet-empowered PDA gadget, and the rest is history. Application empowered the iPhone and gain control over the business sector (PocketNow)Read MoreNegative Effects Of Digital Appliances1236 Words à |à 5 Pagesprominent. Digital addiction and cyberbullying can lead to serious life-changing health issues. In our ever-growing technological world, more digital appliances are starting to have negative effects on consumers. Children that have lived with technology their whole lives are becoming more dependent and more fixated on their digital appliances than earlier generations. They are the first to have an anytime and anyplace kind of connection to technology. With the development of mobile phones, internet chatroomsRead MoreThe Effects Of Cell Phones On Society s Obsession Without Devices837 Words à |à 4 PagesRecent studies suggest that cell phones have evolved into something more than a simple communication tool, gaining its own place in various aspects of social interaction. For instance, a qualitative study on Australian adolescents revealed that cell phones play an integral part in the lives of young Australians (Walsh, White, Ross, 2008). Some of the participants in the study reported very strong attachment to their cell phones; they felt as though their cell phones were part of them. Mozes introduced
Wednesday, December 25, 2019
Research Paper Samples Can Be Fun for Everyone
Research Paper Samples Can Be Fun for Everyone Research Paper Samples - What Is It? Students may also have to verify the truth of the theses before they use them. They often use free dissertations in order to understand the basic format. They also use free thesis examples for many reasons. They should always be aware that essays and term papers have their own unique formats and types of content. Rather than following the exact same topics and evidence which other websites and sources have provided, a good paper is going to get original ideas supported by solid, but innovative evidence. Providing psychological services to police organizations is a rather new phenomenon. Determining the reason behind arthritis has been shown to be hard, but there are a number of factors that can cause it. Carrying out research on companies is extremely essential for learners since it allows them to find research paper services from the most trustworthy and appropriate businesses. Click the one which you like to see the most. Students should remain sure the totally free dissertations they're using are accurate, higher quality, and contain the proper formatting requirements. Keep the aforementioned guidance in mind to be certain that the paper you're relying on is a quality one. Furthermore, the tips will allow you to compose the paper efficiently without a lot of effort. Additionally, you can release the last payment to the writer only after you have gotten an approved custom research paper in full. In other instances, a totally free term paper on the internet is provided as an instance of a professional writing service's work to be able to encourage seekers of term papers to employ the provider's services. If you are searching for top essay writing companies, try out the mentioned above. The most frequently encountered paper writing service that the bulk of our clients require is essay writing. You're much better off finding samples on the internet. The increa sing number of essay writing services is totally overwhelming. Even though a research paper is most likely the most typical academic assignment students want to complete at various steps of their education, most still have issues with choosing good research paper ideas. For students to discover the resources that are proper for them, they should determine the reason why they will need to have a term paper free of charge and what they will use it for. To get an idea, they can study free research papers online. Other students may work with an on-campus writing center to be able to come across completely free papers that will enable them to enhance their work. If you are pleased with the standard of offered samples, you're welcome to put an order at our website. Each customer will receive a non-plagiarized paper with timely shipping. Therefore, it runs with amazing accuracy with no downtimes. Research paper is quite a challenging job to finish but adhering to an obvious mla pr oper structure will allow you to avoid all potential mistakes and will teach you the way to gather and analyze data in an easy and quick way. Don't forget you will have to conduct research work on this issue you finalize. Every student demands help with homework from time to time. When writing a research paper most students choose to use all the probable ways to simplify the assignment and save a little time and nerves. Things You Won't Like About Research Paper Samples and Things You Will If you'd like research paper to contain all the needed info, have a very clear structure and grab attention of the audience, you'll need to obey a very clear structure and provide all the vital details to be sure your paper mla paper taken seriously. An excellent paper will have unique ideas. Researching a paper necessitates digging around and using information from different folks to align to your very own unique ideas and ideas. A very good academic paper would make certain that the impo rtant words provided fits in the notion of the topic perfectly well. Research Paper Samples: the Ultimate Convenience! Moreover, our English-speaking writers make sure every order has original content and a suitable structure. It is normal for a site offering completely free essays to have a searchable database of hundreds of reports so that students can observe examples of a number of essay forms on a number of unique topics. Students should always verify info in a term paper at no cost just to make certain that the info is accurate. Other students may use totally free term papers as a way to learn about the content that ought to be included in their very own document. How to Choose Research Paper Samples There are a number of reasons why a student might need to reference a free essays'' term paper for a class. Students should also make sure the completely free essays and term papers they reference are not merely accurate, but also well-written. Some students search for t erm papers for free so they can use samples of term papers to make their own documents. Other students may need completely free research papers so they may use the reports as drafts of their very own documents. Whatever They Told You About Research Paper Samples Is Dead Wrong...And Here's Why If you're thinking that you will need someone to compose my essay at this time, you can just rely on our honest reviews. When you first begin writing essays in school, it is not uncommon to have a whole topic assigned to you. In summary, learning how to compose essays properly is something which you can't avoid. There are lots of essay writing services that think they're the very best, and therefore don't be cheated and check the genuine collection of the very best. The Honest to Goodness Truth on Research Paper Samples It's extremely important to be aware that you should be adept enough to understand the job at hand, firmly grasp the fundamentals of the format and begin composing the e ssay with the support of the framework the academic paper sample is providing. Also, if you're utilizing the example to assist you, you shouldn't trust the standard of work from examples containing poor spelling and grammar. Moreover, you should also mention which sort of sample you're doing like convenience sampling etc.. Some of the greatest research paper introduction samples incorporate primary resources supporting the argument or research of the issue. For instance, if a student requires a research paper on accounting, the business should assign the writer who's a holder of degree in accounting. Many students try to find term papers for free when they want to observe an illustration of what a report appears like. You're able to purchase term papers and feel the advantages that are given below. There are several reasons why students utilize completely free term papers.
Tuesday, December 17, 2019
The Moral Responsibilities of Multinational Corporations...
Multinational companies like Caltex have a moral obligation to improve the living conditions of the citizens who live and work in those countries. Their role cannot be limited to increasing shareholder value, while perpetuating and fortifying political regimes that persecute and discriminate a group, or groups of their citizenry. I liken this to reforestation, and the responsibility that governments and corporations have to our planet. A corporation cannot simply make a profit and deplete natural and human resources; it needs to give back to that country and its communities. Under South Africas apartheid government, the Black majority was not given the same opportunities to life, liberty and the pursuit of happiness as the Whiteâ⬠¦show more contentâ⬠¦Ã¢â¬ ¦ By investing in South Africa, American companies inevitably strengthen the status quo of white supremacy. â⬠¦ The leasing of a computer, the establishment of a new plant, the selling of supplies to the military all have political overtones. â⬠¦ And among the countryââ¬â¢s white community, the overriding goal of politics is maintenance of white control. In the words of Prime Minister John Vorster â⬠¦ ââ¬Å"We are building a nation for whites onlyâ⬠(Velazquez, 2006, p. 58). Although I have spent my entire adult life in business, I am certain that I would have supported each of the stockholder resolutions that ââ¬Å"the Interfaith Center on Corporate Responsibility announcedâ⬠as ââ¬Å"some of its subscribing members owned stock in Texaco, Inc. and in Standard Oil Co. of California (SoCal).â⬠(Velazquez M. , 2006, p. 59). As the text further states, ââ¬Å"Caltex was actively supporting policies that were unjust because they laid burdens on Blacks that Whites did not have to bearâ⬠(Velazquez, 2006, p. 59). As a proponent of justice and peopleââ¬â¢s rights, I do not agree with the ââ¬Å"utilitarian standard of moralityâ⬠(Velazquez, 2006, p. 59). I view the horrors of apartheid in a similar fashion as I view the Holocaust. As far as the resolutions are concerned; Caltex to terminate its operations, Caltex not to sell to the military or police of South Africa, and Caltex to implement the TutuShow MoreRelatedMultinational Corporations1110 Words à |à 5 PagesEthical Dilemmas for Multinational Enterprise: A Philosophical Overview Part One: Review Question #1 Multinational Corporations have always been and are currently now under harsh criticism. They are mainly condemned for exploiting resources and workers of third world countries, taking jobs away from the US industry, and destroying local cultures. Although there are negatives of multinational corporations, there are also positives. Business done overseas provides jobs for the people of theRead MoreRole Of Mncs As A Political Actor1225 Words à |à 5 Pageseconomies in the world, 51 are now global corporations, only 49 are countries1.â⬠Furthermore, the united nationsââ¬â¢ body estimates that multinationals account for one quarter of the worlds GDP1. While one may not accept GDP as a measure of a nationââ¬â¢s power, it is a prime determinant of its capabilities and limitations as a political actor. The same can be said for MNCs, which have been on the rise since World War II. This discussion focuses on the role of MNCs as a political actor within, between andRead MoreW hat Are the Sources and Limits of Mnc Power1627 Words à |à 7 PagesWhat are the sources and limits of MNC power? Multinational Corporations in a Global Economy IR 120 - 201136597 - Catharina Knobloch 1. Introduction As MNCs are getting increasingly important as actors in political bargaining, the purpose of this essay is to provide a (more or less) detailed overview over the sources and limits of the power of multinational corporations (MNCs). In the first section, I am going to lead into this topic by giving some definitions. In addition to that, I amRead MoreEthically Responsible4889 Words à |à 20 Pagesfuture relies on their aptitude to operate globally. Third world countries seek to attract American MNCs for the jobs they provide and for the technological transfers they promise. However, when these MNCs entered into countries to do business particularly in the third World Countries, many American condemn them (Hofffman Frederick, 1995) for exploiting the resources and workers of the Third World. MNCs are blamed for the poverty and starvation. How ethically responsible should these companies beRead MoreThe Theory And The Maximisation Of Economic Efficiency1595 Words à |à 7 Pagesrelationship. Although the nature of multinational corporations (MNCs) as capitalist enterprises makes them a force for progress in terms of maximizing economic efficiency, that same nature is problematic when considering a wider under standing of progress. MNCsââ¬â¢ potential to be a force for progress ultimately depends on the country and industry that is concerned, but it is important to understand ââ¬â excluding any normative considerations of moral responsibility ââ¬â that MNCs are businesses, and thus seek profitRead MoreHow A Mnc Effect Or Effected By Home Host Country Environment1344 Words à |à 6 Pagesof this report is to define understand how a MNC effect or effected by Home Host country environments. Due to increasing global competition, changes in economic political system business organisation are facing rapid change in business environment. The world is separated politically financially into 200 countries separate countries where each country has its own laws, judiciary system and boundary regulations. We will be discussing how a MNC adapt these differentials and contribute to improveRead MoreBusiness Ethics and Rules Essay1231 Words à |à 5 PagesPersonally, I agree that Solomon s ethical fundamentals are a good moral foundation for a business. ââ¬Å"Business ethics is the study of what constitutes right and wrong (or good and bad) human conduct in a business context.â⬠(p25) From the lecture, we know that ethics matters because ââ¬Å"how organizations behave have important implications for how they fulfill their social and economic rolesâ⬠and ââ¬Å"their success as well as the success of their employees, customers, etc.â⬠Thus, running a business ethicallyRead MoreNigerian Development : The Face Of Oil Extraction And How Mncs Such As Shell Essay1593 Words à |à 7 Pagesbe the countryââ¬â¢s most economically marginalized region. A significant impetus of these tumultuous changes has been multinational oil corporations like Shell that have been extracting oil in Nigeria since 1956. This paper seeks to examine Nigerian development in the face of oil extraction and how MNCs such as Shell have played a role in the countryââ¬â¢s develop ment. I will argue that MNCs, specifically Shell, have had an adverse effect on development within Nigeria as a result of oil extraction and theRead MoreBusiness Ethics and International Business3026 Words à |à 13 Pagesï » ¿QUESTIONà : Business and Ethical practices/Issues in International Business and the role of Multinational enterprises (MNEs) Introduction to Business and Ethics The ethical-related issues have represented the foundation of different religions and life styles. Ethics can be found in all aspects of human activity as the individuals have been preoccupied with the quality of their behavior towards the people around. Even if they do not purposefully intend to improve their relations with the othersRead MoreBusiness Practices And Modern Development2019 Words à |à 9 PagesIs a multinational corporation doing business in a developing country obligated to pay its employees (contracted or subcontracted) a living wage? Today we live in a globalized society; in the recent times world has became a single magnificent globalized village but blinded by all the success we sometimes ignore the cost of turning into a global society. Powerful multinationals have played a huge part in globalizing us and much of the development in recent history can be attributed to these huge
Monday, December 9, 2019
Death by Chocolate free essay sample
Owen uses imagery, symbolism and other figurative methods to develop the perceptions of desolation and mourning in his sonnet Anthem of Doomed Youth. How well does he do this? Anthem of Doomed Youth by Wilfred Owen uses imagery, symbolism and other figurative successfully to create the perceptions of desolation and mourning. Owens poem shows perspectives from both the battle front where the soldiers fight and the home front where the women and children wait for the soldiers to return. For those who die as cattle, the simile used here creates imagery f huge waves of men getting slaughter Just as the cattle would at a Slaughter House.This gives a strong sense to his poem as it is very powerful yet dark. The fallen soldiers fall like pawn on a chess board, this creates the mourning side of this sonnet as it is sad when a soldier falls and there no time to do anything about it. We will write a custom essay sample on Death by Chocolate or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Only the monstrous anger of the guns, the use of personification here makes the guns seem like the people on the battlefield full of anger. The sounds of the guns shooting make a very loud and angry sound monster like giving them the sense that the guns are he monsters of the battlefield.The guns of the battlefield deal massive damage against soldiers, the monstrous anger make you think of a monster, one which you will try and go after your life. The pallor of girls brows shall be the pall, this Is referring to the lonely maidens at the home front waiting for their men to return or any news from them. They are all pallor as they wait as the news for them Is usually not always pleasant. The pall Is the top of a coffin as referring In this sense the girls worry a lot about their men that they take their feelings to the grave with them. The tone used In this poem Is very depressing, Owen has not look at the positive side of the war and only all the negatives parts that overwhelm everyone. What candles may be held, the there are so many fallen soldiers that there Just Isnt enough time and space to hold a single candle for each of them. Through this poem we can see how the war can Impact on many people, everywhere no matter where you are. Many lives are lost at these wars and people weep over these lost friends. Owen has successfully develop the perceptions of desolation and mourning In his poem.
Sunday, December 1, 2019
Issues, concerns, and challenges in environmental adjucation in the philippine court system free essay sample
Introduction The court system is an integral part of environmental enforcement in the Philippines and has made many important contributions to the field. However, environmental cases do not always progress smoothly through the judicial system. This paper is intended to identify important legal issues in the judicial system that affect or limit environmental adjudication. 2 The issues are divided between access to and competency of justice, and legal procedures. While many of these issues could be analyzed further, this paper will highlight the ones to which attention should be paid in any more comprehensive study of Philippine environmental case law. 3 This paper will also use examples and case studies from the United States to illustrate important legal points, since the U. S. and Philippines have similar legal systems. II. Issues A. Legal Procedure and Rules of the Court Because of their unique and complex nature, environmental cases are sometimes hindered by legal mechanisms and rules of procedure designed for non-environmental cases. We will write a custom essay sample on Issues, concerns, and challenges in environmental adjucation in the philippine court system or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page These include rules on standing and class action suits that often do not take into account the fact that environmental damage impacts all citizens. Furthermore, the nature and science of environmental violations often means that statutes of limitations, evidentiary rules, and burdens of proof are not suitable. Some of these issues can be handled internally by the judicial system by instructing lower courts to apply rules liberally. The impact of all of these issues, and how many actually present problems for plaintiffs, is crucial. 1. Standing of Plaintiffs and Citizens Suits In environmental cases, a plaintiff may not necessarily be legally injured in the traditional sense by an act of environ-mental destruction to impair his livelihood. For example, plaintiffs cannot recover damages for fish killed by pollution because they lack standing, despite the obvious economic loss they suffered. 4 While the destruction of natural aesthetic beauty is a moral outrage that indirectly harms all citizens, under traditional legal standing person no would have standing to sue. 5 Furthermore, environmental laws are designed to prevent catastrophic harm that is often not imminent or contained to one geographic area, as opposed to the narrow, immediate harms that provide the basis of most standing requirements. 6 Strict rulings on standing could stifle environmental enforcement, especially since the Philippines lacks sufficient enforcement capacity and personnel. The Philippine Supreme Court has held that standing requires: Such personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court depends for illumination of difficult constitutional questions. 7 The plaintiff himself must have some cognizable and redressable injury. Litigating for a general public interest, or ââ¬Å"mere invocationâ⬠¦ of [plaintiffââ¬â¢s] duty to preserve the rule of lawâ⬠¦ is not sufficient to clothe it with standingâ⬠¦. â⬠8 However, the standing requirement is considered a technicality that courts may waive if the case concerns a ââ¬Å"paramount public interest. â⬠9 In its dictum in Oposa v. Factorum, the Court said that children might even have intergenerational standing to sue to prevent the destruction of forests for future generations. 10 There are questions as to the strength of these to reduce the standing threshold for environmental plaintiffs. While courts may waive technical standing provisions when a case deals with a paramount public interest, it is not required to do so. 11 Furthermore, judges may reasonably differ on what constitutes a ââ¬Å"paramount public interestâ⬠since there is no overriding theme o define it. For example, in Kilosbayan, the Court found that determining the legality of an online lottery system fell within this definition, whereas in Integrated Bar, it held that determining whether deploying marines for crime deterrence violates the Constitution does not. 12 The Court did reduce some of this ambiguity in Oposa by declaring that the right to a balanced and healthful ecology concerns nothing less than self-preservation and self-perpetuation, presumably a ââ¬Å"paramount public interest. â⬠13 However, because the Courtââ¬â¢s discussion on standing in Oposa was dictum, neither this claim nor the right to intergenerational standing is binding law upon the lower courts. 14 Without further guidance from the Court, it is likely that many lower court judges would be reluctant to act boldly by declaring that a particular issue is a ââ¬Å"paramount public interestâ⬠and would deny standing. Congress tried to reduce the standing threshold with citizen suit provisions in environmental statutes, but these have been of limited use thus far. First, only the Philippine Clean Air and Ecological Solid Waste Management Acts contain citizen suit provisions;15 notably, the Philippine Clean Water Act, enacted after these two laws, does not. 16 Second, citizens still bear the risk of paying a winning defendantââ¬â¢s attorneyââ¬â¢s fees, which could be costly enough to discourage even valid suits. Most importantly, these suits are still subject to the ââ¬Å"actual controversyâ⬠requirement of the Constitution. 17 What this means in the context of citizen suits has not yet been heavily litigated in the Philippines. However, lower court judges often require plaintiffs to show actual injury in the narrow or traditional legal sense. 18 Likewise, when prosecutors deputize citizens to enforce a suit, judges sometimes insist that such deputization is only valid for a single case or even invalid under the Rules of the Court. 19 As a result, citizens suit provisions have been largely unused. 20 Standing under environmental laws is hotly contested in the U. S. 21 The U. S. has put citizensââ¬â¢ suit provisions into almost all of its environmental laws. 22 Plaintiffs are required to show 1) an injury in fact, 2) causation between the injury and the defendantââ¬â¢s actions, and 3) redressability in court. 23 NGOs can sue upon a showing that any of their members would have had standing to sue. 24 The focus is not on the injury to the environment, but rather the injury to the plaintiff or NGO representing him. However, the injury can be economic or non-pecuniary, including aesthetic or recreational value. 25 The Court also held that civil penalties payable to the U. S. Treasury serve as redress as they deter polluters. 26 Causation is often the more difficult element to prove, which will be discussed below in à § 4. In New Zealand, the Environment Court has taken a more radical approach. It has eliminated formal standing provisions, requiring only that a plaintiff have a greater interest than the public generally in a controversy or that he represents a relevant public interest. 27 This makes citizen enforcement very easy. However, one might also be concerned about whether this would overburden the court; granting standing is a fine balance between permitting valid environmental claims and risking frivolous litigation. 2. Class Actions and Large Number of Plaintiffs As the notorious mudslide at Ormoc in 1991 and Marcopper mine tailings in Marinduque show, injuries from environmental damage can be grave, costly, and affect a huge number of persons. 28 Even in less publicized events, the number of injured persons may often make individual litigation burdensome and complex. Furthermore, some members of an injured class may be too poor to prosecute their claims individually. Class action suits can facilitate litigation of such situations by providing for: [T]he protection of the defendant from inconsistent obligations, the protection of the interests of absentees, the provision of a convenient and economical means for disposing of similar lawsuits, and the facilitation of the spreading of litigation costs among numerous litigants with similar claims. 29 Other studies have shown that class action suits can provide important social benefits and encourage citizen enforcement to supplement agency regulation. 30 Class actions may the discourage attorney disloyalty that encourages lawyers to plea bargain for less than the actual injury. As happened in the Chinese poachers case in Palawan, lawyers or prosecutors may not seek full compensation for the damage caused because they have an incentive to expend less time and money on a small case. 31 However, because class actions provide aggregate incentives for lawyers, and fees and settlements undergo higher judicial scrutiny, such ââ¬Å"disloyalâ⬠settlements are less likely to occur. 32 While the Philippine Rules of the Court provide for class action suits,33 judges will sometimes be reluctant to certify classes and instead treat the injuries of plaintiffs as separate, despite any common questions of law or fact. In Newsweek, Inc. v. IAC, the Supreme Court ruled that a defamatory remark directed at 8,500 sugar planters do not necessarily apply to every individual in a group, and therefore are not actionable as a class action. 34 Likewise, a judge might refuse to certify a class of pollution victims because they suffer different types of physical injuries, even if the source was the same pollution. In a more litigated legal system, there would be more case law to guide judges on the appropriateness of class actions. However, in the Philippines, this does not yet exist. Add to this the high cost for lawyers, and class actions become even less feasible for most Philippine plaintiffs. 35 In the U. S. , it is much easier to litigate environmental class action suits. The Supreme Court has clearly instructed courts to construe its class action rules liberally and encourage class action suits. 36 This limits judicial discretion in refusing to certify classes to only extreme situations. Furthermore, the rules allow plaintiffs to join by default rather than affirmatively. 37 For environmental cases, the courts will look at the potential number of plaintiffs or the size of the estimated areas that a pollutant has infected to see if plaintiffs have met the numerosity requirement, but they are not required to meet a certain minimum number. 38 For the Philippines, which, unlike the U. S. , has too few environmental class action suits, adopting some of these mechanisms may create a more efficient adjudication process for plaintiffs, defendants, and the courts. 3. Statute of Limitations and Delayed Injuries Unlike a traditional tort or crime, many environmental injuries are not discrete events but only manifest themselves after many years. Pollutants may build up in soils, waters, or human bodies for years without reaching a dangerous level. Cleanup of such sites can take even longer. For example, when the U. S. military left Subic Bay in 1992, it left behind hazardous waste sites with contaminated water that continue to poison the land over a decade later. 39 However, for environmental torts, the statute of limitations is four years, a relatively brief time. This could preclude the litigation of injuries from pollutants with an onset delayed for many years. Thus far statutes of limitation issues have not been a significant factor in environmental litigation. The Philippine Supreme Court addresses similar problems in other fields of law with the discovery rule, allowing the statute of limitations to run when the plaintiff actually or should reasonably have discovered the injury. 40 However, as the courts handle more brown environment cases, it will have to address the tensions between punishing past violators and protecting defendants from time-barred claims. 41 U. S. courts have adopted the due diligence discovery rule, particularly for Clean Water Act and wetlands violations. Because immediate detection of pollution or illegal fill into a wetlands is almost impossible, applying a statute of limitations strictly would defeat the remedial purpose of the act. 42 Courts try to effectuate the Congressional purpose of the statute with the due diligence discovery rule and giving the government a chance to file action against the polluter once the violation is reported to the EPA. 43 Some courts44 realize that a statute of limitation may be inappropriate for cases when pollution continues to cause problems over time. These courts argue that a: Defendants unpermitted discharge of dredged or fill materials into wetlands on the site is a continuing violation for as long as the fill remains. Accordingly, the five-year statute of limitations â⬠¦ has not yet begun to run. 45 The statute of limitation will not run for as long as the pollution remains. Many courts will also treat common law tort nuisances as continuing violations. 46 This approach has the added benefit of allowing the government to fine violators for each day the pollution remains, capturing the more of the costs of environmental destruction. 47 Much of U. S. case law regarding the effect of statutes of limitations on environmental issues comes from ambiguities in the statute of limitation for complex processes, particularly the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), or Superfund law. 48 Because Congress anticipated the complexity and long-term nature of site cleanups, it structured the statute of limitations in a flexible manner, allowing the court hear an initial cost recovery action prior to issuing a declaratory judgment to avoid letting the statute run. It also allows the plaintiff to file subsequent cost-recovery actions to recapture further response costs incurred at the site. 49 However, the lawââ¬â¢s different statutes of limitation for remedial and removal actions phases of the cleanup has led to confusion over how the phases are defined. Courts often defer to EPA determinations in characterizing the type of action due to its technical expertise, rather than making that judgment itself. 50 4. Meeting the Burden of Proof In environmental cases, there may be no line of direct evidence from the perpetrator to the harm. In pollution cases it is often impossible to prove that the plaintiffââ¬â¢s harm was caused by his exposure to the toxic material. 51 For example, if several factories dump pollution into Manila Bay, it is impossible to determine which caused a particular environmental harm. Furthermore, the courts cannot expect absolute scientific certainty on the effects of a health risk such as electro-magnetic fields from power cables. 52 Given these problems, the traditional burden of proof standards, preponderance for civil cases and beyond a reasonable doubt for criminal,53 may prove to be prohibitively high. Philippine courts employ liability-shifting mechanisms to manage this difficulty in environmental cases. For example, pursuant to the Fisheries Code, courts use reverse burden of proof to place the burden of exculpation on defendants found with high-explosive or cyanide fishing gear. 54 Furthermore, the courts have begun to experiment with the precautionary principle, placing the constitutional rights to health and safety above development. 55 The courts also employs res ipsa loquitor in tort suits,56 although this has not been a prominent feature of environmental litigation. Plaintiffs may also hold multiple defendants jointly and severally liable for an act of environmental destruction that cannot be traced to a single defendant company, such as the pollution in Manila Bay. 57 Until recently, Philippine lawmakers did not see a need to introduce a strict liability58 regime into environmental laws. 59 Strict liability was employed in other fields, but not environ-mental laws. More recent anti-pollution laws such as the Clean Air and Solid Waste Management Acts establish that a violation of the standard is actionable through citizen suits. 60 In U. S. , because of its common law tradition, courts are more willing to employ strict liability. Generally, when a defendant, ââ¬Å"though without fault, has engaged in [a] perilous activity â⬠¦, there is no justification for relieving it of liability. â⬠61 Such ââ¬Å"perilous activitiesâ⬠include operating explosives, nuclear energy, hydropower, fire, high-energy explosives, poisons, and other extremely hazardous materials. 62 For citizens suits under environmental statutes, plaintiffs need only show that the law was violated, not prove fault or any actual or threatened harm, without regard to mens rea. 63 When it is impossible to determine the proportion of fault of a large number of defendants, U. S. courts may approximate fault through other indicators, including market share and production output. For example, in Hymowitz v. Eli Lilly Co. , the New York Court of Appeals calculated the size of each defendant drug companyââ¬â¢s market share for DES to determine their fault in the injuries caused by the drug. 64 This also allows courts to address injuries sustained in the past by approximating past fault through data available in the present. The Environment Court in New Zealand has adopted an even more radical approach and done away with formal burdens of proof. It focuses instead on obtaining the best possible evidence for a case. This makes it easier for plaintiffs appealing to the court to dislodge an unfavorable opinion from a lower court. 65 While the Philippine Supreme Court may not wish to go this far, the court could more strict liability for hazardous materials and market share liability tools. 5. Damages and Remedies Even if a plaintiff wins damages from a defendant, if the defendant keeps polluting or cutting trees, the damage will continue. 66 In the Philippines, this is particularly problematic as the fines and penalties imposed under law are often not enough to change a companyââ¬â¢s behavior. In order to encourage development, Congress prohibited temporary restraining orders against government projects. 67 Since government infrastructure projects can cause massive damage to ecosystems, this prohibition is significant. Some courts try to avoid this loophole by claiming that the prohibition cannot violate a personââ¬â¢s constitutional right to health or safety. 68 The extent of this loophole is unclear. Finally, even if a plaintiff or prosecution wins its case, most of the time the true costs of the defendantââ¬â¢s actions will not be reflected in the award. Damages in civil cases and punishments in criminal cases generally capture the costs of any suffering caused to humans, not animals or plants. While some settlements may include forcing a defendant to install pollution-control equipment or contribute money to conservation programs, this still likely does not recoup the full extent of damage to the environment. It is difficult to regenerate natural forest, coral reefs, or populations of endangered animals. The judicial system does not have much power to remedy this problem. The decision on the purpose of environmental laws and how much plaintiffs recover is for the Congress. However, it is important for judges to understand that environmental cases deal with only a fraction of the true costs of environmental damage. This may convince some judges to be more sympathetic toward environmental cases. While punishments for defendants may seem exorbitant, understanding the unaccounted costs of environmental damage puts these into perspective. B. Access to and Competency of Justice Aside from the legal issues described above, in any country, there are a host of practical and logistical issues that impede the judicial systemââ¬â¢s ability to handle environmental cases. This includes the lack of financial resources of plaintiffs, particularly in poorer parts of the Philippines. Plaintiffs and their lawyers must also feel safe from physical and financial harassment while litigating their case. On the other hand, both courts and lawyers are often unfamiliar with environmental laws and science, limiting their ability to adjudicate in the field. Finally, court dockets are often congested, and environmental cases are not given priority. The judicial systemââ¬â¢s role in addressing these issues ranges from fairly involved to almost no role. Yet, in attempting to understand environmental adjudication in the Philippines, it is crucial to recognize the role these practical realities play. 1. Financial Costs of Adjudication In any legal system, filing and litigating a case takes an enormous amount of time and money. Philippine courts impose a filing and transcript fee, although these are waived for citizens suits. Reflecting on his experiences, famous environmental attorney Antonio Oposa suggested that these costs were the greatest inhibitions for most plaintiffs. 69 Furthermore, for injunctive remedies, plaintiffs must post a bond to cover the defendantââ¬â¢s potential damages, which may be too large for a poor plaintiff with livestock and property as his only assets. 70 Most Philippine lawyers do not use a contingency fee system, so plaintiffs must be able to pay for legal services up front and over the lengthy litigation process. 71 On top of this, there is the risk of financially crushing harassment suits from defendants, or Strategic Lawsuit Against Public Participation (SLAPP). Even the logistics of feeding and housing witnesses, and their lost time from work, poses significant problems for predominantly poorer plaintiffs. In the U. S. , NGOs often receive enough donations to allow them to engage in litigation and have staff lawyers. More importantly, plaintiffsââ¬â¢ attorneys often work on a contingency basis, allowing poorer plaintiffs to avoid large financial risk. Furthermore, NGOs and environmental groups seeking injunctive remedies are often required only to pay a nominal bond or may be exempted completely. 72 While some might worry this makes litigation in the U. S. too easy, it drastically improves poor peopleââ¬â¢s access to justice. Pursuant to the Constitutionââ¬â¢s emphasis on the poor, the Supreme Court of the Philippines has taken some efforts to alleviate this problem. Poorer plaintiffs are exempted from paying docket, transcript, and other fees and are granted free legal counsel. Furthermore, the Court provides an annual grant to the Integrated Bar of the Philippinesââ¬â¢ Free Legal Aid Program. 73 However, not all environmental plaintiffs qualify as poor, particularly NGOs, even though they often have limited financial resources. Furthermore, even though the amount of the bond is under the discretion of the judge, judges are reluctant to do this because they worry about being accused of abusing their discretion. 74 2. Harassment of Plaintiffs and Lawyers Because of the high stakes involved in environmental cases, defendants may go to extraordinary means to intimidate and harass plaintiffs and their lawyers. It is not uncommon for defendants to lodge harassment or SLAPP suits against environmental plaintiffs or DENR prosecutors to attempt to force them to drop their charges. 75 Enforcers who confiscate the equipment of criminals are often sued for robbery. 76 Some defendants take even more extreme means such as physical violence or even murder. 77 Such dangers were recently illustrated by the murder of environmental advocate Elpidio de la Victoria and death threats against attorney Oposa. 78 This makes lawyers unwilling to take on difficult environmental cases. To stifle SLAPP suits, the courts should promptly apply the anti-SLAPP provisions in the Philippine Clean Air and Ecological Solid Waste Management Acts when applicable. 79 This means dismissing any harassment suits as quickly as possible. However, plaintiffs relying on other laws have less protection. 80 Congress must expand the use of anti-SLAPP provisions to other environmental laws. Furthermore, law enforcement must vigorously prosecute any defendants who resort to violence. In short, to facilitate environmental cases, the court must protect the ones bringing the cases. 3. Technical Knowledge Among Judges and Attorneys Judges must decide questions of science as well as law in order to dispose of most environmental cases. This is particularly true for brown issues, which involve uncertain science regarding the exact effects of a pollutant. In the U. S. , scientific understanding of pollutants led to new classes of trespass and tort suits that held emitters liable for their actions. 81 However, both sides in a case will try to use any scientific uncertainty to their advantage, or even create scientific uncertainty even when it does not exist in order to confuse the court. Judges must understand what scientific evidence should be admitted and what is not valid. 82 Judges and lawyers need to understand the science well enough to determine which arguments are unfounded and which are plausible. Because general the courts have general jurisdiction and are not specialized in environmental issues, this problem will have to be addressed by providing judges and lawyers with supplemental training in environmental sciences and law. PHILJA and other organizations are already successfully doing this. 83 Eventually, however, this problem may be resolved through a change in the adjudication system. If the Philippines moves toward environmental courts or administrative adjudication84 (as is being considered), judges would be trained specifically to handle environmental cases. 4. Obtaining and Preserving Evidence For green issues, preserving evidence may be difficult. After an illegal logger or fisher is captured, DENR can confiscate the logs and fish. These goods rot or deteriorate over time. Proper procedure requires taking pictures of the logs and fish for admission into court. Specially trained fish examiners prepare reports on the cause of death of fish. When done correctly, this preserves the evidence for use at court. However, some areas may not have fish examiners on hand or the prosecution may not properly prepare the pictures for admissible evidence. It is not uncommon for custodians of the confiscated items to lose track of them over time. Because cases take so long in the court system, this can be a real problem. 85 It is also difficult for enforcement agents to find and confiscate the equipment and vehicles used in environmental crimes, as the boats and trucks perpetrators use are highly mobile. Despite the inconvenience it may cause defendants, such equipment must be held as evidence and to prevent further environmental damage. The accused, or unindicted conspirators, will often petition for the release of their equipment. 86 Unfortunately, sympathetic lower court judges may sometimes grant these requests, despite the contravening case law. 87 Moreover, prosecutors must have the vehicles stored in a safe area despite the lack of storage space. Finally, it is important for enforcers to determine the location of violators, particularly close to the boundaries of natural parks. Community enforcers may not be trained in determining the exact location of where they apprehended the violators. Wealthier units can use GPS, but often the location of apprehension is disputed. 88 Any doubt in this area can destroy the prosecutionââ¬â¢s case. 5. Docket Congestion In many countries, including the Philippines, courts are overburdened with cases. Yet, the Philippinesââ¬â¢ forests and animals are already disappearing quickly. Irreversible damage to ecosystems can occur much more quickly than the many years it may take the court system to resolve a case. As Prof. La Vina noted, the environment cannot wait for the court system. 89 According to Justice Nazario, the Philippines needs over 300 trial court judges to fill the vacancies and resolve pending cases. 90 Low pay discourages the few who are qualified. Many of these vacancies are in remote parts of the country, such as Nueva Ecija, Occidental Mindoro, and Surigao Norte, where much of the fishing and forestry violations occur. Furthermore, the Supreme Court is burdened by the large amount of cases granted review each year, including the automatic review for death penalty cases. 91 Given this burdensome congestion, environmental cases are not given any special treatment on their own merits. Criminal environmental cases may be somewhat more expedited because they involve criminal punishments, but most judges and lawyers show no urgency with regard to environmental cases. 92 The Supreme Court attempted to alleviate this problem with Administrative Order No. 150B-93, setting up special courts to handle illegal logging, but these remain underutilized. 93 Until cases can move through the court system more quickly, the enforcement of environmental law will be delayed. III. Conclusion This paper has highlighted important legal and practical issues preventing efficient adjudication of environmental cases in the Philippines. However, due to logistical and budgetary constraints, this paper focused mostly on case law from the Supreme Court and the personal experiences of lawyers. In order to fully understand environmental adjudication throughout the court system, further research should ideally analyze environmental cases from all Municipal and Regional Trial Courts, Courts of Appeal, and the Supreme Court. It is important to see how cases area actually treated, particularly with respect to the issues examined in this paper. Furthermore, there may be important regional variations, particularly between areas with more natural resources and more urban areas. Even before such a study is undertaken, the courts can apply several lessons from this paper in the near future. First, while the courts have already taken commendable steps to waive filing fees and other costs for paupers, as mentioned above the definition of pauper may be under inclusive by not including NGOs. The courts should consider other definitions to reflect the realities of environmental NGOs. 94 Second, the Supreme Court should instruct the courts to dismiss SLAPP suits expeditiously. While the natural resource laws may not have anti-SLAPP provisions, Congress clearly did not intend to encourage such suits and there is nothing legally preventing the courts from dismissing them faster. Finally, the courts can address standing for citizens and class action suits. In particular, it should set out a clear position on standing in environmental cases. Other challenges will require long-term planning for the courts. Reducing the docket congestion is critical to expedite justice, although doing this will likely take years and require more judges. Likewise, the ongoing effort to train judges and lawyers in environmental law and science must continue, particularly as new judges and lawyers enter the judicial system. The courts should also familiarize themselves with the legal mechanisms available to them, particularly in shifting the burden of proof. However, this will be most useful in pollution cases as they become more common in the future. Ultimately, the challenges described above will require multifaceted solutions from various stakeholders in the Philippine legal system. For example, Congress must work to improve standing and citizens suit provisions in other environmental laws. To reduce the financial risk of brining a suit, law firms could move toward a contingency fee system. Furthermore, it is the responsibility of DENR and environmental agencies to ensure that evidence is properly recorded and preserved. Finally, as the Philippine grows and wealth spreads, more plaintiffs will be able to undergo the financial costs of adjudication. Eventually, the best solution to these challenges may come not from within the courts but from a new adjudication system. The U. S. has worked successfully with administrative adjudication for environmental issues in the EPA and Department of Interior. Other countries have set up independent environment courts. Based on the results of further studies and the needs of the country, the Philippines may move to adopt one of these models. This would allow expert adjudicators to handle cases under rules that make sense for environmental issues. Finally, it is important for judges at all levels of the judicial system to understand the severity of environmental degradation in the Philippines. The only redress environmental plaintiffs or prosecutors may have is in their court. Thus, they should not be reluctant to grant standing or award large damages, when appropriate, because doing so will ensure that both humans and the environment have their proper day in court.
Subscribe to:
Posts (Atom)