Most and Least Important Factors in the Outbreak of Ww1

Which was the most important and least important factor in the outbreak of the First World War? In my opinion, the most important cause of the First World War was the Alliance System. By 1914, the main powers in Europe had been divided into two groups. These were: The Triple Alliance – Germany, Austria-Hungary and Italy, and The Triple Entente – Britain, France and Russia. Although the point of creating these alliances was to avoid war, they meant that any conflict that broke out would increase in scale immediately because the other countries had to support them. The main rivalries were Germany and France over the capture of Alsace-Lorraine, Russia and Austria over the Balkans, and Britain and Germany over their navies and economic power. The Alliance System created a lot of competition between the rival countries, and possibly even the allies themselves, because, naturally, they all wanted to be the most powerful and influential in their group. This just increased the tension between everyone and strengthened each side for the inevitable war. On the other hand, I think the least important cause of the war was the Arms Race. The growing divide in Europe (caused by the Alliance System) had led to an arms race between the main countries. The French and German armies had more than doubled their forces, and all nations were making plans for war. The German Count Alfred von Schlieffen had come up with the Schlieffen Plan, which was to fight France and defeat them within six weeks, and then to turn back and defeat Russia. Unfortunately for them, they relied too much on hoping Russia would take more than six weeks to mobilise, which didn’t happen. Also, as the Germans went through Belgium to get into France, Belgium had a treaty with Britain which meant Britain automatically got involved. Austria was intimidated by Russia and needed Germany to succeed in defeating France, so they could then help them in fighting Russia. Russia had potentially millions of soldiers. This made them very powerful because they could overwhelm the opposition with sheer numbers, although they would have needed Britain’s industrial help because they were badly-equipped. France had a large, well equipped army. They had a plan called Plan 17. This was to charge across the frontiers and deep into Germany, forcing them to surrender. Britain was closely but secretly in collaboration with the French. They set up the BEF (British Expeditionary Force), which was 150,000 highly trained soldiers that could go and support France at any time. Although the Arms Race seems to have developed the preparations for war from each country, I don’t think that it actually caused any more problems between the countries. At this point, war was seen as inevitable and all the nations could do was prepare for what was to come as best as they could.

Study Notes †Balance management Essay

Customer Flow: Taco Bell serves on average 1,500 customers per day (15 hours). On average there are 75 customers in the restaurant (waiting to place the order, waiting for the order to arrive, eating, etc.). How long does an average customer spend at Taco Bell and what is the average customer turnover? R=1,500 customers/day I=75 customers T=I/R=(75 cus/1,500 cus/day)x(15 hrs/day)x(60min/hr)=45 minutes Customer turnover=1/T=(1/45 min)x(60 min/hr)x(15 hrs/day)=20 times per day Job Flow: The Travelers Insurance Company processes 10,000 claims per year. The average processing time is 3 weeks. Assuming 50 weeks in a year, what is the average number of claims â€Å"in process†? R=10,000 claims/yr T=(3 weeks)/(50 weeks/yr)=3/50 yr I=RT=(10,000 claims/yr)Ãâ€"(3/50 yr)=600 claims Material Flow: McDonalds’s holds raw hamburger meat an average of three days before its cooked and sold to customers. The typical inventory of raw meat is 2,500 lb. What is the average amount of hamburger McDonald’s goes through in a week and what is the takt time of processing hamburger in a 15-hour day? R=I/T, R=?, T =3 days=3/7weeks, I=2500lbs, R=2500lbs/ 3/7weeks R=5,833lbs/week, Takt =1/R 1/5833 lbs/week x 7days/week x 15hr/day x 60min/hour = 1.08min/lb – means none of the processes can take more than 1.08min Monetary Flow: For the new Euro introduction in 2002, Wim Duisenberg had to decide how many new Euro coins to stamp by 2002. Euroland’s central banks’ cash-in-coins handling was estimated at â‚ ¬300 billion per year. The average cash-in-coins holding time by consumers and businesses was estimated at 2 months. How many Euro coins were to be made? R=300 B/yr T=(2 months)/(12 months/yr)=1/6 yr I=RT=(300 B/yr)x(1/6 yr)=â‚ ¬50 B Cash Flow (Accounts Receivable): A wholesaler sells $300 million worth of clothes and accessories to retailers per year. The average accounts receivable is $45 million. What is the average billing to collection process cycle time? T=I/R=($45 M/$300 M/yr)x(52 wks/yr)=7.8 weeks A general manager at Baxter states that her inventory turns three times a year. She also states that everything that Baxter buys gets processed and leaves the docks within six weeks. Are these statements consistent? No, because if the flow time is 6 weeks, then inventory turns should be 1/T=(1/6 wks)x(52 wks/yr)=8.7 turns/year. 1. Registration: Average Inventory = 20, Throughput = 20 per hour, Average flow time = 20 / 20 = 1 hour Triage: Average Inventory = 5, Throughput = 20 per hour, Average flow time = 5 / 20 = 0.25 hour, Admit: Average Inventory = 10, Throughput = 5 per hour(25%of20), Average flow time = 10 /5 = 2 hours Average time spent by people admitted = 1 + 0.25 + 2 = 3.25 hours Routine: Average inventory = 10, Throughput = 15 per hour (75%of20),, Average flow time = 10/15 = 0.6667 hour Average time spent by routine care patients = 1 + 0.25 + 0.6667 = 1.9167 hours Average time in ER for all patients = 0.25(3.25) + 0.75(1.9167) = 2.25 hours OR 2. In this case we have: Average Inventory = 20 + 5 + 10 + 10 = 45, Throughput = 20 per hour, Average flow time = 45 / 20 = 2.25 hours. Inventory turns can be calculated using financial statements by dividing COGS (R) by average inventory value (I), linking flow time (an operational measure) to financial measures. With a decrease in total assets (such as inventory, accounts receivable, and plant & equipment), return on assets (ROA) improves. Flow Time = Inv/COGSInv Turns= COGS/Inv

Biographical/Historical Influences Essay

Frankenstein, also known as ‘The Modern Prometheus’, is written by a British author Mary Wollstonecraft Godwin – Shelley during her teens. The novel’s theme is leavened with a few characteristics of Gothic and Romanticism. Based on â€Å"Frankenstein, Or, The Modern Prometheus† (Shelley), the title is alluded to an inventor, Victor Frankenstein, who has an ability to create life of a man whom he calls ‘monster’ afterwards. Moreover, the long arguments with regard to the significance and originality of the story always come along the way; thus, this paper unfolds the real essence of the story—what does it signify for the modern readers; and how do words of the story flow along with the connotations; its influences and so on. Given the list of influences and/or events from Mary Shelley’s life, it becomes quite easy to identify and distinguish how these impacts have prospered to the entire conception of the novel. One of the influences concern the arguments of his father, Godwin in Political Justice, in which he argues that decisions made concerning who lives and dies should be made by those scientists and doctors that are completely impartial. In addition, the impacts of Godwin’s pieces of writing in Shelley’s philosophical thoughts become undeniable, indeed. Her father created a certain philosophy in which the presence of responsibility is inevitable: â€Å"The true perfection of man was to attain, as nearly as possible, to the perfectly voluntary state; that we ought to be, upon all occasions, prepared to render a reason of our actions; and should remove ourselves to the furthest distance, from the state of mere inanimate machines, acted upon by causes of which they have no understanding,† (â€Å"Political Justice 2: 519-528,† Godwin). Hence, as an analysis of the entire view, it becomes quite easy to determine all the responsibilities, which are accountable for every individual’s behavior such as those of Frankenstein. One of the impacts that should also be acknowledged is that which concerns her father’s disapprobation of the rise of technology; stating that its existence would diminish the need for human beings to cooperate with each other—making it less and less necessary to work together. In other words, such a view concerns dealing with reliability on the information technology: â€Å"Responsibility in the contemporary world and with the awesome power of technology which may be used for good or evil has changed. We cannot evade the responsibility that comes with this change — the responsibility to use technology wisely, not only for the sake of our patients but also for the sake of the future. In a sense, we need to be able to foretell the future, to re-enunciate norms and standards as substitutes for the norms and standards left behind by technology. If we fail to do this, the future is bleak,† (Loewy). In other words, development of the high and sophisticated technologies may bring a number of troubles in various means, as seen in the Frankenstein’s work. Moreover, the creation of the novel also comes along with an influence concerning Mary Wollstonecraft (Shelley’s mother) who refers Frankenstein to Prometheus who attempts to give the power of the gods to humanity. In her novel, the appearance of the ‘monster’ is a scientific blame in which the creature dares to imitate God: â€Å"Nature in every thing demands respect, and those who violate her laws seldom violate them with impunity,† (â€Å"Vindication of the Rights of Woman,† Wollstonecraft). Hence, the laws of nature should make the boundaries of everyone’s behavior; Victor Frankenstein surpasses such boundaries like the new sophisticated technologies. Cited Works Loewy, Erich. â€Å"Textbook of Medical Ethics. † NY: Plenum Medical Book Company, 1989, p. 69 â€Å"Political Justice. † bilkent. edu. February 2, 2009. Shelley, Mary. â€Å"Frankenstein, Or, The Modern Prometheus. † Broadview Press Edition 2. Eds. David Lorne Macdonald and Kathleen Dorothy Scherf. Melbourne, Australia: The University of Melbourne, 1999. 364 pp Wollstonecraft, Mary. â€Å"Vindication of the Rights of Woman† pp 138-139. sa

Annotated Bibliography Strategic Management Literature review - 1

Annotated Bibliography Strategic Management - Literature review Example The author credits that business plan and a business idea will make a company or business achieve its goals. A personal conclusion is that cost leadership or product differentiation, which would result in added value to the product or good offered to the buyer creating room for high incomes and profit. The author tries to show how people critically think to build a successful business and that is the author gives a hint on the successful ways and that is by having a business plan. The author classifies management as the school of thoughts that show management in different institutions. Mintzberg own proposal for the basic values of strategic management is criticized by using the identical criterion. The intended audience by the writer is business and people who intend to get into the business venture. The author’s purpose of the work was the show strategy paradigm where the typical planning focus for the firm prepares the financial budget with a time perspective of 12 months. The credibility of the author is that strategic management aim is to create, affirm aim and do data analysis in order to identify issues arising in the organization (Hill, et.al 2009). Special features include the collection of data entails making efforts of collecting data from other organization and even carrying out reviews from the outside environment and this is quite unique. The author concluded that survival, practical goals and operational goals must be enhanced by stakehol ders. The author’s conclusion of the work was the strategy paradigm creates good financial management.A personal conclusion is that strategic paradigm is a way of performing financial management that grows the company’s economy and growth. A theme of the study was to focus on how business is run by the microcomputer and these are the relationships that are accorded in business. Weaknesses are the challenging factors that an organization will face, altering the smooth flow of production strategies.  

Virtual Teams. Eastern Europe Assignment Example | Topics and Well Written Essays - 750 words

Virtual Teams. Eastern Europe - Assignment Example A good way to determine which are best investment locations within Eastern Europe is by comparing the gross domestic product per capita of the Eastern European countries. The countries with the top three gross domestic products per capita in Eastern Europe are Slovenia, Czech Republic, and Slovakia. The corresponding gross domestic product per capita of each of these countries is illustrated in the table below. Country Gross domestic product per capita Slovenia $27,149 Czech Republic $21,028 Slovakia $17,630 (Globalpropertyguide). The country with the highest gross domestic product per capita could be considered the most attractive location by a lot of business analyst because the customers in that country have higher buying power. Another important variable to consider are the market and industries that the country has to offer. In Slovenia the service industry accounts for 64% of Slovenia gross domestic product and manufacturing and mining are key economic sectors (CultureGrams). T he majorities of companies in Slovakia are state control which leads to a lot of inefficiencies. Tourism in the Czech Republic is a booming industry. The Czech Republic is the best selection among the different Eastern European nations. This country has a diversified industry segment which includes glass, metallurgy, machinery and equipment, motor vehicles and armaments (CultureGrams). The use of virtual teams can help companies achieve better business results. The target country the company selected is the Czech Republic. Since the company does not have any experience in the Czech Republic marketplace the firm should contract a consultant to help them in the process of selecting the virtual team. A local firm that specializes in human resources would be very helpful to access the local talent for the virtual team. The team is going to be composed of 8 people. The company is going to include two managers from its corporate headquarters. The remaining six members will be selected amo ng the local population. Each member will have different academic backgrounds. The six professionals the company will select for the virtual team include an engineer, accountant, marketing specialist, researcher, lawyer, and a scientist. The virtual team will work together to analyze the best business opportunities available in the Czech Republic. The goal of the firm is to achieve market growth by expanding into other markets. The virtual team will utilize multiple technological tools and devices to communicate with each other. The online service Skype will be used as the primary communication tool for team meetings. Skype allows people to communicate while at the same time seeing a video stream of the person. All team members will have smartphones. A smartphone such as an Iphone enables its users to transfer data files from phone to phone. One of the cultural differences between the United States and the Czech Republic is the fact that in the United States the official language is English and the Czech Republic the official language is Slavic. It is important for the American members of the virtual team to understand the customs and traditions of the Czech Republic. For instance in the Czech Republic it is customary go greet a person by shaking hands firmly and saying their last names. In the virtual setting the managers must remember to use the last names of the person. First names are only used among relatives and family members. Another sign of respect in the workplace is addressing both men and women by their professional title. The probability of success of the team depends on a lot of factors. One of the most important aspects of the virtual team project is to have excellent communications among the team

Critically discuss the arguments for and against the use of fair Essay - 1

Critically discuss the arguments for and against the use of fair values in the preparation and presentation of financial statements. Cite literature to support your answer - Essay Example As the report explores financial statements need to be comparable from one year to the next and between one company and another. However, even though fair values may be said to be current and therefore more comparable, the fact that judgement need to be exercised brings subjectivity into play. In addition to that, those judgements on which investors and other stakeholders depend have their own agenda. In some cases they may exercise their judgement in such a way as to manipulate the accounts. This therefore brings us back to the reliability of the figures in the financial statements. This essay stresses that the arguments against fair value accounting appear to outnumber those in favour. Most of the arguments against essentially relate to the classification of financial instruments the fair value hierarchy. According to Ernest and Young the 2008 amendment of the International Financial Reporting Standards (IFRS) requires that the classification of financial instruments be recorded at fair value in a hierarchy consisting of three levels. The first levelrelates to quoted prices that have not been adjusted for identical assets and liabilities in active markets. The second level relates to input prices but excludes quoted prices which are included in the first level and which can be observed directly for assets and liabilities, in the form of prices or in the form of derived prices indirectly. The third level relates to both assets and liabilities that are not based on market data that can be observed.

Conflict Resolution Essay Example | Topics and Well Written Essays - 1750 words

Conflict Resolution - Essay Example On the other hand, if conflict lacks effective and timely management, it can prevent a nurses’ ability to ensure quality client care and escalate into violence and abuse (Pines et al., 2012). The essay discusses conflict as a hindrance management and one of the greatest challenges to quality health care provision. Conflict is an inherent component of nursing even though the professional code does not articulate for accepting abuse. Conflict can compromise professionalism among nurses if it escalates to great levels. Nurses must knowledge the variety of ways in which conflict can emanate among them and should be prepared to prevent and manage it in the workplace. Positive conflicts are instances involving contrasting viewpoints that leave the parties involved with useful lessons and wiser than they were before. The first positive aspect of conflict is provision of an outlet that strengthens an intergroup unity. In the nursing profession, working involves agglomeration with other professionals to form a group. A conflict that creates togetherness and unity to such a group to work together in order to realize a particular goal is positive conflict. Group members discuss and manage their interests for improving their wellbeing. Secondly, conflict discourages premature decision making in a team, on the other hand, amongst members of a staff giving participants an opportunity to explore concern and interests at stake. Nurse A had a misunderstanding with her colleague, nurse B; their conflict got a lasting resolution through a series of negotiations that left both the parties happy and contented. After the resolution, the two parties settled and added more energy in order to realize the agreed upon goals. The result was an increase in the general output and productivity. The other aspect of conflict is a negative one. Negative conflicts may have diverse harmful implications. Some of the adverse outcomes have far-reaching consequences on nurses’

The Issue of Marital Rape Research Paper Example | Topics and Well Written Essays - 2750 words

The Issue of Marital Rape - Research Paper Example Norms of the current age are based on equality and respect of each other while maintaining the status of equal partners. In legal and social parlance, it was believed that marriage was an institution in which sex between the partners is always legal irrespective of the fact that the woman is ready for it or not. The man was allowed to use her lady and she was bound by his commands. There was no concept of sexual assault and rape in a marital relationship even a century ago. It is pertinent to note here that a law is an off shot of aspirations of the society in which its citizens decide that how they would view a balanced society and on which ground they would like to judge the other and to be judged. Historically, law –just like other segments of the society- was reluctant to admit any interpretation of forced sex in a marital relationship as a rape. Marriage was considered as a license for a man to have sexual relations with his wife even against her wish. But gradually, now society and the law have evolved otherwise. Marriage is a knot between a man and woman, where both agree to live together for love and continuation of their family through their children. Marriage may be defined as â€Å"An agreement made in due course of law where a man and woman reciprocally decide to live with each other during their joint lives, in the union which ought to exist between husband and wife†1. Marriage is the relationship where cohabitation is not only for the purpose of sexual pleasure only but also for sharing love and grief, hot and cold, and to work for the comfort of life together. The institution of marriage is the oldest and the only permanent institution of any society. It was there when no other institution was there and till today, all the society posses it in one way or the other.  

Foodservice Marketing Assignment Example | Topics and Well Written Essays - 250 words

Foodservice Marketing - Assignment Example They also display their logo (the Golden Arches) that makes it easy for the customer to recognize the brand. At Olive Garden, they do their merchandising in a different way. They do not display their products at the website. Most of their displays are at the restaurants’ menus. One can also contact them to place an order which they deliver to their customers as per the order. It is the same case at Sizzler. Their foods and beverages are displayed at their menu. Another company that merchandizes by displaying their products on the internet is coca cola company. Marketing involves influencing customers to buy your products. A successive marketing technique should meet the customers’ expectations (Garlough, p. 33). McDonalds also has a marketing strategy that has helped it become a force that is difficult to beat in the market. It has a marketing mix that is attractive to many customers. Their prices are ones that most customers are willing to pay. In addition, the company also makes numerous advertisements on TV and newspapers. It also identifies its hotels, which are visited, mostly and this assists it when developing its marketing strategies. They carry out research so as to establish the correct marketing mix. Their service is quick and friendly too (McDonald’s Corporation, p. 2). The marketing strategies in other food service companies are not so different from that of McDonalds. For Sizzler, Olive Garden and Chilis, they all market their products through advertisement in the media and newspapers. Techniques used by companies are extremely influential in getting customers to buy the company’s. In fact, in my perspective I purchased coffee from McDonalds due to the merchandising technique they use to market their products. Attractive displays by a company in their advertisement and merchandising techniques have the ability to attract customers. Restaurants such as Chilis and Sizzler do not have a marketing technique that is as strong as that of

Earmarked Tax in Public Sector Essay Example | Topics and Well Written Essays - 4750 words

Earmarked Tax in Public Sector - Essay Example For instance, earmarking of taxes for protecting the environment is commonly applied in the US, Europe and other western countries. Furthermore, taxes that are collected from fuel consumption and motor vehicles are allocated for the construction of national and state roadways (Anesi, 2003). Furthermore, concerned with the increasing health related issues, World Health Organisation (WHO) has further increased the global tax rate of cigarettes and other tobacco related products to 10% which will ensure an additional revenue generation of 7%. However, the revenue percentage generated can increase in higher income countries compared to lower income countries. However, the members of WHO stated that despite the steep increase in the taxes charged for cigarettes and tobacco products, people are not discouraged in limiting their addiction levels irrespective of the income status of the country (Prakongsai & et. al., 2008). Part 1: Literature Review According to Brett & Keen (2000), earmarki ng has the possibility of affecting the electoral outcome due to the decisions of the policymakers and representative voters. It has been observed in this regard that the policymakers often tend to use earmarking to motivate the voters’ belief in order to earn considerable amount of votes against the competing party. Hence, it can be suggested that earmarking of taxes should either be fully implemented or abolished, similar to the strategies adopted by the Australian government which assigns the entire amount of gambling taxes towards serving a particular purpose (Brett & Keen, 2000). However, Garrett (2001) argued that earmarking of taxes is effective in changing the behaviour of the citizens in most of the countries causing a deep impact over the socio-economic trend. However, it is worth mentioning that if earmarked taxes are diverted from their projected purposes, it can create certain limitations for the policymakers (Garrett, 2001). Therefore, it can be concluded that e armarked taxes can be effective in changing the behaviour of the citizens towards certain products and practices that tend to affect the health of the people by a large extent. As observed by Mossialos & Dixon (2002), healthcare systems are based on dependable factors that have an access to human, consumable and capital resources. Availing these dependable factors require adequate financial resources for establishment cost, adequately compensating the employees offering healthcare services and incurring expenses for drugs and other consumable medicines. Moreover, these measures are fundamentally adopted by the governmental authorities for generating revenue, and managing them in according to their importance. Since, the costs are increasing gradually and resources are being scarce, policymakers are facing huge challenges in attaining funds. Therefore, it can be suggested that containment of costs and increasing the funding can improve the healthcare services (Mossialos & Dixon, 2002 ). According to the findings of Kanavos (1999), the total expenditure on healthcare sector incurred by the UK consists of personal medical services which include ambulatory care, medical goods and in-patient care.

Discipline and Management Essay Example for Free

Discipline and Management Essay Included in this essay is a comparison between discipline and management also behavior and misbehavior. Beginning the essay is a short definition and a short word picture of discipline, management, behavior and misbehavior. Next is a comparison of how each are different, similar, related. Discipline is described in the Merriam-Webster online dictionary as first being â€Å"punishment† or then further down states it is â€Å"training that corrects, molds, or perfects the mental faculties or moral character. † In our text book, Building Classroom Discipline, C. M. Charles states that discipline in the classroom is â€Å"Teachers’ efforts to maintain classroom decorum and secure student’ cooperation and exercising self-control. † Discipline should not be thought of as punishment but instead a learning road of self-control. Discipline is a person’s ability to conduct appropriately or a short word picture could be[pic]. With in the classroom, management is a written plan of action so that class runs smooth. Webster dictionary describes management as â€Å"conducting or supervising of something†. Management is the process of controlling and discipline is the act once management has failed. Management and discipline are interrelated and work together to for a common plan and a smooth ran class. If there was no [pic] (management) designed the discipline would not work. Webster’s dictionary states that behavior is â€Å"the manner of conducting oneself†. Behavior described in our text book Building Classroom Discipline â€Å"is the totality of one’s physical and mental activities. † Behavior is everything that we do whether good or bad. One word that best describes this is[pic]. Misbehavior is considered as a person’s actions â€Å"that disrupt teaching, interfere with learning, demean others, or otherwise violate the moral codes of society. † (C. M. Charles 2008 p13) In Webster’s dictionary they describe misbehavior as â€Å"a bad manner of conducting one self. † Both of the terms are related however [pic] (misbehavior) is the disruption of behavior as a whole. Behavior is the bigger picture and misbehavior is a smaller unit within behavior. The two are interrelated and you can not have one with out the other. With the appropriate action taken in advance misbehavior could be minimized. There are different types of misbehavior and some are more serious than others but none of the less takes away from instruction. This is why it is very important to have a discipline plan devised. In the above essay is a comparison between discipline and management also behavior and misbehavior. Beginning the essay is a short definition and a short word picture of discipline, management, behavior and misbehavior. Next is a comparison of how each are different, similar, related. To complete this essay is a short description of why it is important to have a discipline plan.

Pennsylvania Sovereign Immunity Statute Essay Example for Free

Pennsylvania Sovereign Immunity Statute Essay Rooted in the history of common law in England was the immunity of the sovereign from the processes of the law (Christie and Meeks, 1990). However, this idea of some man or body of men above the law was said to be objectionable to the English concept of justice (Christie and Meeks, 1990). â€Å"The King can do no wrong† was often the explanation for the said immunity but denoted more the lack of adequate redress at law than absence of capacity to violate the law (Christie and Meeks, 1990). Thus, the agitation for the availability of tort remedy against the sovereign, or the state to any considerable degree led to the mature development of the law (Christie and Meeks 1990, page 1202). Because of the increase in the scope of governmental activities and the expanding activities of the Federal Government which touch upon the life of every citizen in such an intimate manner, pressures to either abolish the state’s immunity from suit or to have a waiver of the sovereign immunity in limited situations, increased (Christie and Meeks, 1990). The Pennsylvania Sovereign Immunity Statute has been one of those which hoped to address the increasing dissatisfaction with the concept of sovereign immunity from suit (Christie and Meeks, 1990). This paper hopes to explain the Pennsylvania Sovereign Immunity Statute and the exceptions provided for under the said statute. The paper would also present the particular Constitutional provision which provides support for the exception to the Sovereign Immunity. Finally, the paper hopes to present case laws, the venue, process and limitations, in order to explain further the exception to the said immunity statute. Pennsylvania Sovereign Immunity Statute Over three-fourths of the states in the United States of America have either totally abolished the doctrine of sovereign immunity or substantially modified it (Christie and Meeks, 1990). One such example is Pennsylvania which provides for exceptions to the doctrine of sovereign immunity. 42 Pa. C. S.  §Ã‚ § 8521-8528 provides for the Sovereign Immunity in general, the exceptions and the limitations on damages. 42 Pa. C. S.  § 8522 (b) provide for acts which may impose liability which include: Vehicle Liability or the operation of any motor vehicle in the possession or control of a Commonwealth party; Medical-professional liability or acts of health care employees of Commonwealth agency medical facilities or institutions or by a Commonwealth party who is a doctor, dentist, nurse or related health care personnel; Care, custody or control of personal property in the possession or control of Commonwealth parties, including Commonwealth-owned personal property and property of persons held by a Commonwealth agency; A dangerous condition of Commonwealth agency real estate and sidewalks, including Commonwealth-owned real property, leaseholds in the possession of a Commonwealth agency and Commonwealth-owned real property leased by a Commonwealth agency to private persons, and highways under the jurisdiction of a Commonwealth agency; Potholes and other dangerous conditions of highways under the jurisdiction of a Commonwealth agency created by potholes or sinkholes or other similar conditions created by natural elements; The care, custody or control of animals in the possession or control of a Commonwealth party, including but not limited to police dogs and horses and animals incarcerated in Commonwealth agency laboratories; the sale of liquor at Pennsylvania liquor stores by employees of the Pennsylvania Liquor Control Board created by and operating under the Liquor Code, if such sale is made to any minor, or to any person visibly intoxicated, or to any insane person, or to any person known as an habitual drunkard, or of known intemperate habit; National Guard activities or acts of a member of the Pennsylvania military forces; and finally, the administration, manufacture and use of a toxoid or vaccine not manufactured in the Commonwealth under conditions specified by the statute (42 Pa. C. S.  §Ã‚ § 8522 (b)). Under the Pennsylvania Constitution, all courts shall be open and every man for an injury done him in his lands, goods, person or reputation shall have remedy by due course of law, without sale, denial or delay, and suits may be brought against the Commonwealth in such manner, in such courts and in such cases as the Legislature may by law direct (Pa. Const. Art. I,  § 11). Hence, under this provision the general assembly waives sovereign immunity which is a bar to an action against commonwealth parties where damages would be recoverable under the common law or statute creating a cause of action if the injury were caused by a person to whom the defense of sovereign immunity is not available (Westlaw, n. d. ). Exceptions to the Sovereign Immunity The first exception to sovereign immunity is the vehicle liability or the operation of any motor vehicle liability in the possession or control of a Commonwealth party (42 Pa. C. S.  §Ã‚ § 8522 (b)). Motor vehicle means any vehicle which is self-propelled and any attachment thereto, including vehicles operated by rail, through water or in the air (42 Pa. C. S.  § 8522 (b)). In Harding v. City of Philadelphia, 777 A. 2d 1249 (Pa. Cmwlth. 2001), the Court held that bicycles are not motor vehicles (Governor’s Center for Local Government Services, 2003). In determining whether the vehicle is in operation, the Supreme Court held that the dispatcher’s directions do not constitute operation under the vehicle exception (Regester v. Longwood Ambulance Company, Inc. , 797 A. 2d 898 (Pa. Cmwlth. 2002)). In another case, the Court held that citys negligent maintenance and repair of fire departments rescue van was â€Å"operation of motor vehicle† within meaning of motor vehicle exception to governmental immunity (Mickle v.  City of Philadelphia 550 Pa. 539, 707 A. 2d 1124 (1998)). The Court further explains in the case of Vogel v. Langer, 569 A. 2d 1047 (Pa. Cmwlth. 1990), that â€Å"operation necessarily entails momentary stops due to traffic and communication with other drivers, or such acts which are an integral part of the operation itself (Vogel v. Langer, 569 A. 2d 1047 (Pa. Cmwlth. 1990)). The second exception provides for the medical-professional liability or acts of health care employees of Commonwealth agency medical facilities or institutions or by a Commonwealth party who is a doctor, dentist, nurse or related health care personnel (42 Pa. C. S.  §Ã‚ § 8522 (b)). In Williams v. Syed, No. 431 C. D. 2001, the Court held that Dr. Syed has no privilege to claim sovereign immunity as a defense because as Chief Medical Director of State Correctional Institute at Pittsburgh, he falls within the medical professional liability (Williams v. Syed, No. 431 C. D. 2001). In the case of Stack v. Wapner, 368 A. 2d 292 (Pa. Super. 1976), patients successfully sued physicians for their negligent failure to monitor the patients after administering certain drugs (Stack v. Wapner, 368 A. 2d 292 (Pa. Super. 1976)). The third provides for the personal property exception, which is under the possession or control of the Commonwealth. The Court held that personal property must directly cause plaintiff’s injury not just facilitate it (Dept. of Environmental Resources v. Myers, 581 A. 2d 696 Pa. Cmwlth. (1990)). In this case, a helicopter pilot brought an action for injuries incurred when, under contract with the Department of Environmental Resources (DER), his helicopter ran into power lines while spraying for gypsy moths (Dept. of Environmental Resources v. Myers, 581 A. 2d 696 Pa. Cmwlth. (1990)). The pilot alleged that DER negligently placed the balloons marking the boundaries of the area to be sprayed as well as negligently providing him with a typographical map that failed to show the power lines (Dept. of Environmental Resources v. Myers, 581 A. 2d 696 Pa.  Cmwlth. (1990)). Because of the negligent placement of the balloons and the incorrectly marked map, the pilot contended those items of the Commonwealths personal property directly caused his injuries (Dept. of Environmental Resources v. Myers, 581 A. 2d 696 Pa. Cmwlth. (1990)). Rejecting that argument, the Court held that the placement of the balloons did not cause the injury, but merely facilitated another kind of negligence which is professional incompetence (Dept. of Environmental Resources v. Myers, 581 A. 2d 696 Pa. Cmwlth. (1990)). The fourth provides for the real property exception which is under the care, custody or control of the agency. The Court in a case held that the scroll saw was realty, taking into account the nature of the saw, the status of it with respect to the realty, the manner of annexation, and the use for which the scroll saw was installed (Cureton ex. rel. Cannon v. Philadelphia School District, 798 A. 2d 279 Pa. Cmwlth. 2002). In Collins v. City of Philadelphia 227 Pa. 121, 75 A. 1028, Pa. 1910, the Court held that the hole, six inches square, near the middle of a narrow sidewalk and in the direct line of ordinary travel, was more or less dangerous to all persons passing, whether walking or on skates (Collins v. City of Philadelphia 227 Pa. 121, 75 A. 1028, Pa. 1910). Thus, the girl whose foot went into the opening which resulted in permanent injuries, is within the exception provided by the statute (Collins v. City of Philadelphia 227 Pa. 121, 75 A. 1028, Pa. 910). The fifth exception provides that a dangerous condition of highways under the jurisdiction of a Commonwealth agency created by potholes or sinkholes or other similar conditions created by natural elements, shall be an exception to the sovereign immunity but the claimant must establish that the dangerous condition created a reasonably foreseeable risk of the kind of injury and that the Commonwealth agency had actual written notice of the dangerous condition of the highway a sufficient time prior to the event to have taken measures to protect against the dangerous condition (42 Pa. C. S.  §Ã‚ § 8522 (b)). In Litchfield, 22 D. C. 4th 123 (C. P.  Clinton 1994) in that the Pennsylvania Department of Transportation has the responsibility to make a highway under its jurisdiction safe before it can transfer that jurisdiction, and that whether the highway was safe at the time of transfer is a factual issue for the jury (Litchfield, 22 D. C. 4th 123 (C. P. Clinton 1994)). The sixth exception provides for the care, custody or control of animals in the possession or control of animals in the possession or control of a Commonwealth party to which the Commonwealth may be held liable (condition (42 Pa. C. S.  §Ã‚ § 8522 (b)). In a case, the Court held that the City of Philadelphia was not in control of a stray dog that attacked the plaintiff under the exception because a stray dog was not within the possession and control of the City (Jenkins v. Kelly, 498 A. 2d 487 (Pa. Cmwlth. 1985). Furthermore, the Court also held in another case that the fact that a township had investigated prior attacks by a dog, owned by a private citizen, and had even temporarily quarantined the dog on one of the occasions, did not create â€Å"possession or control† of the dog, when, at its owner’s premises, the dog attacked her guests (Lerro ex rel. Lerro v. Upper Darby Tp. , 798 A. 2d 817 (Pa. Cmwlth. 2002). The seventh exception provides that liquor store sales at Pennsylvania liquor stores by employees of the Pennsylvania Liquor Control Board if such sale is made to any minor, or to any person visibly intoxicated or to any insane person, or to any person known to any person known as a habitual drunkard or of a known intemperate habit then, Commonwealth cannot use as a defense, sovereign immunity (42 Pa. C. S.  §Ã‚ § 8522 (b)). Acts of members of the military forces are also included in the exception from the sovereign immunity statute (42 Pa. C. S.  §Ã‚ § 8522 (b)). In a case, the Court held that the proposition that the Supreme Court held that the supremacy clause of the United States Constitution prevents a state from immunizing state acts from liability imposed under federal holding that because the Pennsylvania Sovereign Immunity Act does not immunize the unnamed defendants from a cause of action created under federal law, the action cannot be foreclosed merely because the conduct of the defendants does not fall within any of the exceptions to immunity (Heinly v. Commonwealth, 153 Pa. Cmwlth. 599, 621 A. 2d 1212, 1215, 1216 (1993)). Finally, the last exception provides that the liability may be imposed on the Commonwealth for a toxoid or vaccine not manufactured in Pennsylvania and Pennsylvania must take responsibility for it (42 Pa. C. S.  §Ã‚ § 8522 (b)). The statute provides for the following additional guidelines, that the toxoid or vaccine is manufactured in, and available only from, an agency of another state; the agency of the other state will not make the toxoid or vaccine available to private persons or corporations, but will only permit its sale to another state or state agency; the agency of the other state will make the toxoid or vaccine available to the Commonwealth only if the Commonwealth agrees to indemnify, defend and save harmless that agency from any and all claims and losses which may arise against it from the administration, manufacture or use of the toxoid or vaccine; a determination has been made by the appropriate Commonwealth agency, approved by the Governor and published in the Pennsylvania Bulletin, that the toxoid or vaccine is necessary to safeguard and protect the health of the citizens or animals of this Commonwealth; the toxoid or vaccine is distributed by a Commonwealth agency to qualified persons for ul timate use. Hence, the Court held that to apply this exception, there must be a strict interpretation based on the legislature’s intent (Jones v. Southeastern Pennsylvania Transportation Authority 565 Pa. 211, 772 A. 2d 435 (2001)). Venue, Process and Limitations As provided in 42 Pa. C. S.  § 8523, actions for claims against a Commonwealth party may be brought in and only in a county in which the principal or local office of the Commonwealth party is located or in which the cause of action arose or where a transaction or occurrence took place out of which the cause of action arose (42 Pa. C. S.  § 8523). The statute adds that if venue is obtained in the Twelfth Judicial District (Dauphin County) solely because the principal office of the Commonwealth party is located within it, any judge of the Court of Common Pleas of Dauphin County shall have the power to transfer the action to any appropriate county where venue would otherwise lie (42 Pa. C. S.  § 8523). The service of process in the case of an action against the Commonwealth shall be made at the principal or local office of the Commonwealth agency that is being sued and at the office of the Attorney General lie (42 Pa. C. S.  § 8523). Limitations on damages is also stated in 42 Pa. C. S.  § 8528 wherein damages arising from the same cause of action or transaction or occurrence or series of causes of action or transactions or occurrences shall not exceed $250,000, in favor of any plaintiff or $1,000,000 in the aggregate (42 Pa. C. S.  § 8528). Furthermore the types of damages recoverable are those damages recoverable only for: Past and future loss of earnings and earning capacity; Pain and suffering; Medical and dental expenses including the reasonable value of reasonable and necessary medical and dental services, prosthetic devices and necessary ambulance, hospital, professional nursing, and physical therapy expenses accrued and anticipated in the diagnosis, care and recovery of the claimant; Loss of consortium; Property losses, except that property losses shall not be recoverable in claims brought pursuant to section 8522(b)(5) which relates to potholes and other dangerous conditions (42 Pa. C. S.  § 8528). In all these, suits against an agency of Pennsylvania may prosper once the plaintiff provides that his claim is under one of the exceptions provided for under the statute. The sovereign immunity therefore under the Pennsylvania Sovereign Immunity Statute is not at all absolute and persons may file suits if their cla ims fall under one of the exceptions provided.

UK Anti-Terrorism Laws Analysis of Key Concepts

UK Anti-Terrorism Laws Analysis of Key Concepts The UK Home Office holds plenty of different legislative functions that are used to help prevent any terror attacks from happening. Their main strategy used to counter terrorism is called Operation contest, it involves four detailed criteria to ensure that any attacks are successfully prevented. Firstly, it aims to Pursue or follow terrorist activity in order to be able to stop terrorist attacks. Secondly, it wants to Prevent people from becoming terrorists, or actively supporting terrorist movements. Thirdly, Home Office aims to Protect the public and strengthen the safeguarding levels used to protect the nation from such attacks as the ones in France. Finally, the last element of the criteria is to Prepare. This stage is a last resort for when an attack cannot be stopped, and its intention is to mitigate the impact of the attack as much as is possible in order to fulfil the other criteria to an effective standard. The prevention of terrorism is more relevant now than ever before, considering recent attacks, such as the ones in Nice this year. The Anti-Terrorism, Crime + Security Act 2001 (ATCSA) implemented the Indefinite detention of international terror suspects, in an attempt to gain further control over the issue. S.21 of this Act declares that the Secretary of state may issue a certificate in respect of a person, if they reasonably believe that a persons presence in UK is a risk to national security, and they suspect that the person is a terrorist. This is a useful prevention method, because detaining possible suspects means that they cannot partake in any dangerous terror related acts. However, there are some issues concerning the detainment of individuals, especially when it is not certain that the individual has been identified as a terrorist. In order to pass the legislation, the government had to derogate from Article 5 of ECHR, which deals with the right to liberty for individuals. (AV Secretary of State Home Department 2004)[1] It is argued that even a suspected international terrorist must still be given certain rights, for example they can use S.21 to appeal to the Special Immigration Appeals Commission against the allegations made against them. The detainment of falsely accused suspects in particular could cause conflict within todays modern society; Lord Hoffman claimed that the real threat to the life of the nation, in the sense of a people living in accordance with its traditional laws and political values, comes not from terrorism, but from laws such as these. To emphasise this point, Lord Scott said that indefinite imprisonment that is based on ground s that are not disclosed and made by a person whose identity cannot be disclosed, is the stuff of nightmares. This raises doubt to the sincerity of governmental intentions regarding terrorism suspects, and the success rate of finding and stopping active terrorists from causing irreparable damage. Following the ruling of the House of Lords, the government replaced the provisions of ATCSA 2001 with the Prevention of Terrorism Act 2005 (PTA) This introduced various changes and new methods, such as control orders for all terror suspects; these can be implemented whether the suspect is British or foreign, which has introduced a higher level of equality towards the treatment of suspects. This Act stipulates that control order means an order against an individual that imposes obligations on him. For purposes connected with protecting members of the public from the risk of terrorism. The obligations that may be imposed by a control order made against an individual, are any obligations that are necessary for purposes connected with preventing or restricting involvement by that individual in terrorism-related activity. The PTA allowed the statute to impose non-derogating control orders on individuals, which included electronic tagging, curfews, visitation restrictions, internet bans, and limits placed upon phone communication. (Secretary of State for home Department V JJ 2007)[2] A control order is not the same thing as being placed under house arrest. The sole purpose is to put a stop to any potential terrorist activity, and they are tailored to each individual case in order to be a successful prevention method. They can be imposed for a period of up to 12 months at a time, but then an application for renewal must be made. This is a highly effective strategy to prevent terrorists from being able to plan or stipulate any attacks. Because it cuts off, or at least monitors all communication between the detainee and the outside world, it means that the individual has no way of executing any sort of attack, via his own actions or through somebody elses. It is a good and effective method hat is reasonably accessible too, which theoretically should be a highly effective prevention strategy, once a suspect has been identified. Despite the effectiveness of the method, Lord Bellingham likened the conditions of a control order to that of prison, simply without the benefit of association with others. He questions the humanity of the control order, and whether it is ethically acceptable to place an individual under these conditions, especially when it has not been proven that they have committed a crime. However, in contrast to this, Lord Brown noted that provided the core element of confinement does not exceed 16 hours a day, it is insufficiently stringent as a matter of law to effect a deprivation of liberty. This means that by law it is acceptable to allow the use of such a method, where the affected individual is a threat to the welfare of the nation. Beyond 16 hours, however, liberty is lost, and the problems with the control order are entirely valid. Article 6 (1) of the European Convention of Human Rights (ECHR), addressed the issue of a defendants rights in regards to a fair trial. In the determination of his civil rights and obligations, or of any criminal charge against him, everyone is entitled to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law. Judgement is openly accessible in the interest of the public eye, but the press and public may be excluded from all or part of the trial itself in the interest of morals, public order, or national security in a democratic society. Everyone charged with a criminal offence shall be presumed innocent until proven guilty according to the law. In addition, everyone charged with a criminal offence has the right to be informed promptly, in a language which they understand and in detail, of the nature and cause of the accusation against them. They have the right to defend themselves in person, or through legal assistance of their own choosing, and also to examine or have examined witnesses against them and to obtain the attendance and examination of witnesses on their behalf under the same conditions as witnesses against them. The House of Lords held that Article 6 (1) of the ECHR did apply to the control order proceedings, meaning that the suspect would be entitled to a fair and public hearing, along with the other criteria mentioned. (Secretary of State for home Department V MB, AF 2007)[3] Lord Billingham said that in regards to any case in which a person was at risk of a control order containing obligations, there could be a fair trial in spite of the fact that a controlled person was neither provided with the detail nor the sources of the evidence, forming the basis of the allegations. Terrorist suspects also have a right to respect for private and family life, and there shall be no interference by a public authority with the exercise of this right. Except when it is in accordance with the law, and is necessary in a democratic society in the interest of national security, public safety or the economic well-being of the country, or for the prevention of disorder or crime. Similarly, no one shall be subjected to torture or to inhuman or degrading treatment or punishment. (G V Secretary of State for home Department 2004)[4] These conditions illustrate the States compliance with acceptance of a suspects individual rights. This brings us to the conclusion that the main importance to the Government is to use the law to aid them in preventing any terrorist acts that could be a threat to the safety of the country. There are various provisions in regards to the reform and abolition of control orders under the Terrorism Prevention and Investigation Measures Act 20011 (TPIM). These include the introduction of a replacement system of terrorism prevention and investigative measures. There have also been increased safeguarding levels for the civil liberties of individuals that are subject to the measure. For example, there is now a higher test that must be satisfied before the measures can be imposed upon suspects; compared to what already exists for control orders, which have a maximum time limit of 2 years for TPIM notices. Further measures can only be imposed if the person has re-engaged in the terrorism. But restrictions that impact on an individuals ability to follow normal patterns of daily life will be kept to a minimum in order to protect the public. They will have to be proportionate and clearly justified in order to keep the public at peace with the State and how effectively they are managing current affairs in relation to the protection of the public regarding threats of terrorism. The Counter-Terrorism and Security Act 2015 is another useful aid in providing legislative measures to prevent terrorist attacks from becoming a reality within the UK. For example, it allows the seizure of passports from persons suspected of involvement in terrorism for up to 30 days. This means that it stops possible suspects from being able to leave the country to avoid capture, but more importantly they cannot get on any flights and commit terror attacks. This Act also allows the imposition of temporary exclusion orders from the UK, used to stop potential threats from executing any plans within the UK that could cause any serious damage or harm to the country. The Police are provided with various legislative measures to assist them in the counter of terrorist acts, such as stop and search powers, which are given to them under s.43 of the Terrorism Act 2000. (TACT) A constable may stop and search a person whom is reasonably suspected to be a terrorist, or to discover whether he has in his possession anything which may constitute valid evidence of terrorism. However, this method has been used less and less in recent years. The Metropolitan Police stopped and searched 411 people in the year of 2014/2015, compared to 2010/11, where 1,154 people were searched, and an even larger total of 1,896 in 2009/10. Lord Carlile of Berriew complained about the effectiveness of it, as it catches no or almost no terrorism material, it has never caught a terrorist, therefore it should be used conservatively. The exercise of this stop and search power was a clear interference of Article 8(1) of the ECHR, which is the right to privacy. As shown in (Gillan + Quinton V UK 2009)[5], it is not in accordance with the law, and therefore not the best method to use when trying to prevent terrorist attacks. Port and border controls are another prevention method used in an effort to keep the country safe from attacks. The State reserves wide powers to stop, search and detain individuals at ports and airports. (Beghal V Director of Public Prosecutions 2015)[6] However, recent changes have reduced the maximum period someone can be questioned before being detained from a 9-hour period to just 6 hours. With access to legal advice for all individuals who are questioned for more than one hour. 32,000 individuals were stopped at ports in the UK in 2014/15. Despite the use of this method being generally avoided, there are other more successful strategies that are used within the UK to prevent terrorism. These defensive strategies have been put in place with the sole purpose of protecting the public of the UK, and gives law enforcement the power to do all they can to prevent such attack as the ones in Nice. Terrorism is defined in the UK by the Terrorism Act 2000 (TACT) within three main subsections.ÂÂ   S.1(a) defines it as the use of threat or action that involves serious violence against a person, serious damage to a property, or endangers a persons life, other than the person committing the action. Terrorism also occurs if the action creates a serious risk to the health or safety of the public or a section of the public, or if it is designed to seriously interfere with or disrupt an electric system.ÂÂ   S.1(b) of TACT stipulates that terrorism also involves the use of threats that are designed to influence the government or an international government organisation, or to intimidate the public. Finally, S.1(c) explains that terrorism occurs where the use of the threat is made for the purpose of advancing a political, religious, racial, or ideological cause. Additionally, the use or threat of action which involves the use of firearms or explosives acts as a count of terroris m, whether it falls within section b. or not. (Regina V F 2007)[7] The general definition of terrorism references criteria such as the intention and motivation of a suspected terrorist, whereas a more specific approach identifies terrorist activities like hijacking and taking hostages. The case of (R V Gul 2013)[8] UKSC 64, made the Supreme Court reconsider the definition of terrorism, as it is arguably far too wide to be an effective prevention method. One person could be seen as a terrorist to a certain number of the population, but to another section such as a conflicting religion or country, they could be seen as a freedom fighter. Because of this, it has been difficult to agree on a definition of terrorism that is suitable for everyone at an international level. The issue in this case concerned the legal definition in TACT and whether or not it includes military attacks by non-state armed groups working against the armed forces during conflict. The Supreme Courts press summary explained how it unanimously dismissed Mr Guls appeal because of a judgment given by Lord Neuberger and Lord Judge, which was agreed by other members within the courts. Mr Gul argued that both domestic law and international law required that the legal definition of terrorism should be narrow and strictly interpreted. This was to exclude its application from situations where it is not necessary, namely those involving actions by non-state armed troops attacking foreign armed forces in their territory. The definition had clearly been drafted in deliberately wide terms so it could take into account the various and unpredictable ways that terrorism might take effect. In these circumstances, the only reason for the Court to interpret the definition more restrictively would be if it conflicted with the ECHR, or generally with the UKs obligations in international law. In parting, the Court noted that although the issue was one for Parliament to decide, the current definition of terrorism is concerningly wide, and needs to be condensed significantly in order to be more productive in its effort to prevent terrorism. However, in contrast to this view, Lord Carlile shares his own views on terrorism in The Definition of Terrorism. (7th June 2007) His main conclusions find that there is not one single definition of terrorism that commands full international approval. The risks posed by terrorism and its nature as a crime are sufficient to necessitate proportional and special laws to assist prevention, disruption and detection. This indicates that the definition of terrorism would be a very useful part of such laws, and the more detail that can be provided, the better. It would provide an easier way to not only define but recognise acts of terrorism and put more effective precautionary measures and laws in place to stop such events occurring. The current definition of terrorism is consistent with international comparators and treaties, meaning it is useful because of how broadly fit for its purpose it is. There are many different ways an individual can commit acts of terrorism, so it makes sense that an efficient definition would be fairly broad or extensive, to cover all possible aspects. For example, the offences against property should continue to fall within the definition of terrorist acts, as well as with religious causes. However, the only religiously inspired terrorist attack in the whole of Europe in 2013 was the murder of Lee Rigby in Woolwich.ÂÂ   This shows that despite its necessity, this part of the definition is not needed very often. But that does not mean that it is an insufficient part of the definition, therefore it should not be discarded or overlooked. The definition being so broad does not bring us to the conclusion that it is unfit for its purpose, if anything it makes it more effective as it c an help to prepare for or determine all or more possible terrorist activities. Alternatively, it could be argued that there is no such need for certain elements of the definition, and that to be more effective it should in fact be more concise. S.1(b) includes actions which are not severe enough to constitute actual acts of terrorism. Therefore, existing laws should be amended so that these actions cease to fall within the definition if they were only intended to influence the specific target audience. For terrorism to arise, influencing actions or reactions is not enough. The root of the word terrorism is taken from a Latin term that means to frighten, therefore, there should be a definite intention to intimidate the target audience, or make them act in a certain way. Even though some sections may be too broad to be effective, extra-territoriality should remain within the definition in accordance with international obligations. This would allow justified prosecutions of terrorist activities in other countries, such as Iraq and Syria. The Terrorism Act is a wide-ranging piece of legislation that criminalises various acts related to terrorism as it defines it. The legal definition of terrorism it provides is so broad it has been argued that it threatens to criminalise most of the general population as well. The UK Governments current independent reviewer of terrorism legislation is called David Anderson QC, who succeeded Lord Carlile of Berriew C.B.E. Q.C. in February 2011. Anderson has expressed some concerns regarding the issues arising with the definition of terrorism. In one of his reports, he argued that the current definition needs to be much more narrow, otherwise simple general affairs such as political speeches or investigative journalism could be incorrectly identified as terrorism. This is not the aim of the definition, it illustrates a good example of why it is too broad, as not only is it broad enough to include all counts of terrorism, it is also so broad that it is incorrectly criminalising many othe r individuals which is an unjustified result of a poorly crafted definition. In another one of David Andersons reports, he discussed ways in which to solve the problems, the necessary actions to narrow it down and become a more applicable definition would be to remove s.1(c), which stipulates that shooters and bombers are deemed to be terrorists even if they are not trying to influence or intimidate anyone other than their immediate victim. This rule is only applicable within the UK, and it does not apply to poisoners, arsonists or people who use cars or machetes as weapons. Therefore, it is arguable that repealing it would not have much of an impact on the current UK legislation regarding terrorism anyway. This deems it a potential solution to discard the particular subsection of the definition in order to condense it and put more focus on factors with higher levels of importance. Ultimately, this would make the definition more fit for its purpose, and there would be less speculation regarding its levels of effectiveness. The UK has some of the most extensive anti-terrorism laws in the western world.ÂÂ   They give Ministers, prosecutors and the police the powers they need to put a stop to violence caused by terrorists. Hate crimes are another example used to illustrate how unnecessarily extensive the definition of terrorism actually is. A hate crime may include something like an indirect act of racism, but it will not always suffice as an act of terrorism. For example, a child making a threat on a fascist website to shoot their teacher would be legally classed as a terrorist. This act is criminally wrong, but if the child only intended to harm that one individual teacher, who would be the only person that would be immediately affected by their act, then it is wrong to characterise them as a terrorist as well. Therefore meaning that the current definition has flaws that need to be amended in order to stop the incorrect determination of terrorists or terrorist activity. When comparing the definitions of terrorism from different countries, it is clear that there are some similarities between the basic structure of the definition. In 1986, France adopted its first anti-terrorism law. As of 2016, the French legal definition stipulates that an act of terrorism occurs if it is connected to individual or collective enterprises, and intended to gravely disturb the public order through the use of intimidation and fear. It defines terrorist acts as deliberate assaults at life and personal integrity. Similarly, the U.S. Code of Federal Regulations defines terrorism as the unlawful use of force and violence against persons or property to intimidate or coerce a government, the civilian population, or any segment thereof, in furtherance of political or social objectives. This definition is arguably a lot more fit for purpose than the extensive version that the UK abide by. In comparison, it could be argued that the narrow definitions are more effective as they a llow clear focus on pinpointing the acts of terrorism to the best of the states ability, enabling efficient prevention of terrorism and harm. These definitions are not dissimilar, so with a small amount of change, the current UK definition could be equally as concise and effective as the others are. The word terrorism itself has a large political stigma attached to it. This could be the reason behind international communities having so much difficulty in finding a universally accepted definition of the term. Most governments do agree that certain key elements of crime are what we use to define an act as terrorism. These elements include a politically motivated act of violence that is used to target non-combatant targets, and is designed to spread fear across a nation or the world. The reason it is so difficult to define is that there are so many different types or ways in which it can occur. However, despite the fact that the current UK definition provided by TACT is extremely broad, it is still fit for its purpose. It is sufficient in catching terrorists and doing its best to prevent terrorism in order to protect the public. The problem is that it is so broad, it can unjustly criminalise individuals as well. To prevent this, some sections of the definition should be condensed i n order to reach a better balance. Bibliography The Definition of Terrorism. (7th June 2007) http://www.hri.org/docs/ECHR50.html https://www.gov.uk/government/collections/terrorism-prevention-and-investigation-measures-act http://claiminghumanrights.org/equality_before_law_definition.html http://login.westlaw.co.uk/maf/wluk/api/tocectory?sttype=stdtemplatestnew=true https://portal.uclan.ac.uk/webapps/blackboard/content/listContent.jsp?course_id=_61833_1content_id=_1566774_1mode=reset [1]ÂÂ   AV Secretary of State Home Department 2004 UKHL 27; [2004] 2 A.C. 368 [2] Secretary of State for home Department V JJ 2007 7] UKHL 46 [2007] 3 WLR 681, [2008] 1 AC 440 [3] Secretary of State for home Department V MB, AF [2007] UKHL, [2007] 3 WLR 681, [2008] 1 AC 440 [4] [5] Gillan + Quinton V UK 2009 50 EHRR 45 [6] Beghal v DPP [2015] UKSC 49; [2015] 3 W.L.R. 344; [2015] 2 Cr. App. R. 34; [2015] H.R.L.R. 15 [7] Regina v F [2007] 3 WLR 164, [2007] 2 All ER 193, [2007] QB 960, [2007] [8] Regina V Gul 2013 UKSC 64

Impetous Actions And Their Tragic Consequences :: essays research papers

Impetuous actions can dramatically alter the life of anybody in many ways. The lack of thinking things through and acting solely on one particular emotion can lead to unanticipated results. In William Shakespeare's Romeo and Juliet, Shakespeare shows how impetuous actions combined with the need for lust can lead to a tragic end. It wasn't fate but rather Romeo and Juliet's hasty actions that brought their untimely deaths. Love at first sight ultimately led to the premature deaths of the two lovers. At the Capulet party was where Romeo first sees Juliet: O, she doth teach the torches to burn bright! It seems she hangs upon the cheek of night As a rich jewel in an Ethiop's ear- Beauty too rich for use, for earth too dear. So shows a snowy dove trooping with crows As yonder lady o'er her fellows shows. The measure done, I'll watch her place of stand And, touching hers, make blessed my rude hand. Did my heart love till now? Forswear is sight, For I ne'er saw true beauty till this night. (1.5.51-60) At the very first sight of Juliet, Romeo immediately falls in love with her. He doesn't begin to think about her character, age, or even about whether she is married. If Romeo had taken his time and gotten to know Juliet and thought about what might come of this attraction, the tragic ending to their story could have been avoided. Romeo is not all to blame for the tragedy. Juliet felt exactly the same way about Romeo when she first saw him: My only love sprung from my only hate! Too early seen unknown, and known too late! Prodigious birth of love it is to me That I must love a loathed enemy. (1.5.152-155) Like Romeo, if Juliet had just taken some time to think things through, this disaster might have never occurred. After the two lovers had met, they made many hasty decisions and actions that only made their circumstances worse. The night the two sweethearts met the decided to get married: Three words, dear Romeo, and good night indeed. If that thy bent of love be honorable, Thy purpose marriage, send me word tomorrow, By one that I'll procure to come to thee, Where and what tine thou wilt perform the rite, And all my fortunes at they foot I'll lay And follow thee my lord throughout the world. (2.2.149-155) The very next day the Romeo and Juliet were married in secret to prevent another fight erupting between the Capulet and Montague families.

Medical Errors :: Health, Miscommunication, Work Loads

In year 2000 Institute of medicine (IOM) reported that around 98,000 people die each year (Kohn, 2000). The main reason for this incident is medical errors. Medical errors cost around $29 billion loss for heath care industry (Slonim, LaFleur, Ahmed, & Joseph, 2003). These medical errors caused people to be more in hospitals, more diagnostic evaluations, un-necessary treatments, and also resulted in many deaths. Medical error is defined as â€Å"failure of planned action to be completed as intended or use of a wrong plan to achieve an aim† (Kohn, 2000). Entering wrong medical information causes adverse effect on drugs and care given to patients. Lack of proper medical record will cause patients to stay more in hospitals, more disability, and more loss for health care industry. Medical errors are considered to be eighth leading cause of deaths in USA (McGowan & Healey, 2009). Of all major departments in health care, one of crucial departments is pediatrics (Kozer, Berkovitch, & Koren, 2006). Pediatric department is one of the key departments in health care sector and comprise of around 10 % of health care industry (McGowan & Healey, 2009). There were many deaths reported in pediatric departments. The medical errors will have more impact on children than in adults due to various reasons. One reason is that most of medicines for children are off label and they don’t have standard doses (Kozer, Berkovitch, & Koren, 2006). Another reason for medical errors is that many doses of medications needs to be adjusted according to child’s weight and body mass. Some medications which are supplied need to be diluted and improper dilatation doses will result in deaths (Kozer, Berkovitch, & Koren). All these medical errors results in abnormal deaths in children. There are various types of medication errors. They are dosing errors which are caused due to improper dosing of medication and tenfold error which are caused due to prescriptions which are ten fold higher or lower in dose than recommended dose (Kozer, Berkovitch, & Koren, 2006). The other types of errors are diagnostic errors which are caused due to delay in diagnostics and error in monitoring test results, treatment errors which are caused due to delay in responding to an illness due to lack of test results and due to other issues like improper system failures and lack of backup plans (McGowan & Healey, 2009). Mostly medical errors are due to increase in work loads, abbreviations misunderstandings, and misinterpretations due to handwriting (Kozer, Berkovitch, & Koren, 2006).

Tourette Syndrome :: essays research papers

Tourette Syndrome   Ã‚  Ã‚  Ã‚  Ã‚  Tourette Syndrome was named for Georges Gilles de la Tourette, who first described the syndrome in 1885. Although the disease was identified in 1885, today in 1996, there still is a mystery surrounding Tourette Syndrome, its causes and possible cures. Tourette Syndrome is a neurological disorder that researchers believe is caused by and abnormal metabolism of the neurotransmitters dopamire and serotonin. It is genetically transmitted from parent to child. There is a fifty percent chance of passing the gene on from parent to child (Gaffy,Ottinger). Those most at risk are sons of mothers with Tourette Syndrome. About three-quarters of Tourette Syndrome patients are male. Males with the disorder have a ninety-nine percent chance of displaying symptoms. Females, have a seventy percent chance of displaying symptoms. This ration of 3-4:1 for males and females may be accounted for by referral bias. Also, there is a frequent number of reported cases within the Mennonite religious isolate population in Canada. The specific genetic transmission however, has not been established. Some researchers believe that the mar is on an autosomal dominant trait. Some cases however are sporadic, and there may not be a link to family history involved. These cases are mild however, and not full blown. The onset of Tourette Syndrome must be before the age of fifteen, and usually occurs after the age of two. The mean age onset of motor tics is seven. The mean age onset for vocal tics is nine. In order for a person to be classified as having Tourette Syndrome they must have both multiple motor tics and vocal tics. These tics however do not have to occur everyday. In fact, affected individuals may rarely exhibit all of the symptoms, or all of the tics. The vocal and motor tics must also occur within the same year, for a person to be classified as having Tourette Syndrome. Symptoms can disappear for weeks or months at a time. However if people afflicted with the syndrome try and suppress their tics, they will re occur with increased ferver. Tics increase as a result of tension or stress, and decrease with relaxation or concentration on absorbing a task.   Ã‚  Ã‚  Ã‚  Ã‚  Tics are classified into two groups: complex and simple tics. Simple tics are movements or vocalizations which are completely uncomprehendable and meaningless to those not suffering from the disorder (Peiss). Complex tics are movements or vocalizations which make use of more than one muscle group to appear to be meaningful (Peiss). Simple motor tics are: eye blinking, head jerking, shoulder shrugging or facial grimacing. Simple vocal tics are: throat clearing, coughing, snorting, baiting, yelping.

Directed Writing †Welcoming Speech Essay

You are the school head prefect and your principal is asking you to prepare a welcoming speech in conjunction with the enrolment of 800 new form 1 students to your school Prepare a welcoming speech and use the following points to assist you in the preparation of your speech: *To ensure the discipline of school is strictly adhered to. *Demerit points awarded to students who breach the code of conduct. *Behave properly and talk politely with seniors and other visitors. *Proper attires at all times,no punk hair/coloured hair. *Get active and enrol in club and socities activities *Strictly no celullar phones. *Maintain and uphold the school acdemic achievements Your speech must follow the proper format. Higher marks awarded on language,presentation and clarity. This text is not edited: You may please identify any grammatical /spelling errors or on ideas and presentation. A very good morning for our beloved principal Mr. Haji Ismail bin Haji Syafiq, respected teachers and all my friends. This morning, I felt very honoured to speak to our junior level 1 about 800 of them. Welcome to SMK Pengkalan Chepa 2, Padang Tembak. You are now members of this school and so it is very important for you to protect the good name of this school. As the Head Prefect of the school, it is my duty and responsibility to ensure that these discipline code are strictly adhered to Firstly , you cannot bring mobile phones, cannot have colored hair, your school uniform must not be tight.The hair should be short and the shoes must be all white.Leather shoes are strictly not allowed except for the prefects where they are allowed to wear black leather shoes.All forms of jewelleries are not allowed to be wear inside the school compound. Remember , If you fail to comply with these regulations,then punishment shall be imposed on you.You will be most likely suspended or expelled from school. The members of this school are encouraged to be polite and well behaved not only among yourselves but also to your seniors in form 2,3,4 and 5.In addition you are also compelled to behave in front of the teachers.If there are visitors such as parents and any officials from any organisation outside there,you are required to wish them and respect them.This is our culture in this school and everybody must behave so that we can uphold the image and reputation of this school. Dear friends, It is also important for you to be enrolled in societies and clubs that we have in this school.We have many of them and some include mathematics,sejarah, english and bahasa melayu.As for the clubs,we have taekwando,silat gayong and chess.You can enrol in clubs and socities that you think,you can carry them until you reach form5. For your information ,this school use demerit points for each offence committed by each student. If the students collect more than 10 demerit points,then the student can be penalized and their parents will be call out. . Remember,. I hope that you all as a new student can uphold the school’s name.

Summary of ‘the Gardener’

When Helen Turrell became pregnant she was ashamed because she was not married. She left her home in England to have the baby in the south of France. When she returned to England, she pretended that the baby was really her brother’s child. The brother, George, lived in India but he had died falling off his horse. This meant that Helen had to look after the child. Helen told other lies. She said that she had to go to the south of France because she was ill. More Summary of Devil at My HeelsShe said the child had been born in India, but had been brought to the south of France by a nurse who had been dismissed when the child became ill, and she also said that she had given the child’s mother some money. The child was called Michael. Helen didn’t tell him that she was his real mother. She said that she was his aunt, and that he was her nephew. Michael was sent to a private school. At school, he was told that he was born outside mirage /illusion/ vision.When the First World War began, Michael joined the army. He did not have to do much fighting, but he was killed by an exploding shell that completely buried his body. After the war, Michael was reburied in a huge cemetery in Belgium. After that, Helen decided to visit the grave of Michael. On her way to cemetery, she met a woman named Mrs Scarsworth, who said that she visited graves for her friends who could not come herself. She took photographs of the graves. Late at night, M rs Scarsworth came into Helen’s hotel room.She said that she was telling lies. Her real reason for visiting the cemetery was to visit the grave of someone special to her (probably a secret lover). On the next morning, Helen visited the cemetery. It was huge; there were thousands of black crosses that all looked the same. Helen did not know how she would find her son’s grave. A gardener approached her. Helen said that she was looking for her nephew’s grave. The gardener said he would show her the grave of her son.

To Appreciate the Nature of Life We Must First Understand the Cell

Life itself is amazing. It surrounds us on a daily basis from the ants in our window seal, the squirrels on the power line, to the bacteria we all have in our mouths and on our bodies. Life is indeed a gift. Every life that comes into this world is made up of cells, life of humans, plants, and animals. I know that to understand the nature of life we must first comprehend the cell, its parts, and organelles. There are two different types of cells, including prokaryotic and eukaryotic. Living bacteria is an example of something that contains prokaryotic cells.Eukaryotic cells are in just about everything, all humans and all animals. I must say that the eukaryotic cell is way more complex than the prokaryotic. A prokaryotic cell does not even hold a nucleus, which is the brain of the eukaryotic cells. Human and animals cells cannot be developed without prokaryotic cells. Even though these two different types of cells are very different they also are somewhat similar. Both contain riboso mes, cell membranes, and cytoplasm. Plant cells are eukaryotic cells but there are items that definitely set them apart. Cell walls, chlorophyll, and vacuoles are difference between the two.By plant cells having these different organelles, they function in a unique order. Each organelle in the cell do different task. Supporting all organelles in the cell is the cytoplasm. Cytoskeleton maintains the shape and gives it strength. The nucleus is a cell’s brain and operating system. The mitochondrion develops energy through cellular respiration. Ribosomes produce protein, while the nucleolus is what makes ribosomes. The vacuole is the largest organelle and it stores food, wastes, and water. The cell wall which is in all cells except animals, protect the cell and allows elements such as water, oxygen, and carbon dioxide to enter.Endoplasmic reticulum is what carries materials through the cell. Lysosomes are what break down large food molecules into smaller ones. Using energy from t he sun to produce glucose is the chloroplast (which can only be found in plant and algae). Cells make up life. We cannot live or operate without them. Each individual cell is like groups of workers that work together. Without the nucleolus which makes the ribosomes, we would not have any protein. And without protein, we as humans could not be healthy. Humans need cells and all their many organelles. Without cells, there is no life.

Media Representatin of Women in Sport

Major Essay Current society is built upon stereotypes and constructions that are predetermined by previous generations’ views. One of the most recognised historical constructions is the patriarchal theory, that the female is subservient to the male. However, this construction of gender power is slowly equalising, with the rise of feminist groups in the latter part of the 20th century giving reason for this occurring. Nevertheless, gender battles are still occurring, particularly in the sporting industry, which remains male dominated. Female sport has been given much notoriety over their uproar in the past decade, but is finding in a male controlled industry it is difficult for women to receive help from governing bodies. Female sport is marginalised compared to male sport, largely due to the sexualisation of the athletes themselves. Professionally they are receiving very little media coverage in comparison to males and in an amateur sense; females are being stereotyped as a result of the images of ‘athletic’ sexualised women displayed in magazines such as Zoo, Sports Illustrated and Alpha. The media has evolved female sport into sexually appealing entertainment and doesn’t give the sports that have not been sexualised, enough coverage. (Maria Sharapova Bikini) The media have constructed their own image of what a female athlete ultimately looks like by posting images in their magazines, â€Å"characteristics favoured in visual media are those commonly associated with feminine beauty, such as smiling, unblemished skin, slender and toned physique, and long blonde hair† (Schell n. d. ). Maria Sharapova pictured below is the perfect example, and even though she isn’t the number one female tennis player and hasn’t been for some time, she is still one of the most popular and most followed players in the women’s circuit, she was the highest paid female athlete in the world come 2006, earning more from endorsements than prize money (Carr 2006). We see in Australia the sexualisation of sports like Netball, where women in the ANZ Championship wear skin tight, short dresses to play, making it appealing to male audiences. We often see at the Australian Open, similar length dresses or skirts that leave little to the imagination. Venus Williams sent the media into frenzy in 2010 with her skin colour underwear visible as soon as she moved around the court, to which she designed herself (Eurosport 2010). Tennis uniforms are becoming a fashion statement more and more every year, which is always judged by the media when someone wears something even slightly risky or sexy. Anna Kournikova was the pioneer in making tennis ‘sexy’ with her risque photographs in the magazine Sports Illustrated (Cover pictured below). Former tennis player and feminist rights activist Billie Jean King gave a response to the Anna Kournikova Sport illustrated photographs with this, â€Å"It doesn't bother me at all if some of the guys come out to watch women's tennis because they want to see a beautiful woman. Who could hold that against Anna? Still, it's unfortunate when others with a high skill factor don't win the endorsements. Sure, the good-looking guys get more endorsements, but the difference in men's sports is that the ugly ones get their share, too. †(Amateur Athletic Foundation of Los Angeles 2000) In America, ‘sexploitation’ is taken to another level at a professional level, particularly in the sports of wrestling and in the gridiron league Lingerie Football League. In these competitions, females wear very little, going down to the bare minimum. Pictured below is an image of the Lingerie Football League, clearly the uniforms (Lingerie Football League 2009)(Anna Kournikova 2000) leave little to be desired, but are used to entertain to a male dominated audience. These sports are both considered to be female sports in their own right, but we also see the sexualisation of women in male sports, particularly in professional sides in the form of cheerleaders. Cheerleaders provide entertainment during the sporting breaks, which we often see during breaks in male sports, providing a view of females in general as sexual objects and inferior to the male ‘athletes’. So from our perspective it is clear that the media has constructed a view that the amateur female athlete must be ‘sexy’ in order to be able to succeed, we don’t read in magazines or see photographs of less attractive female athletes, they have excluded them for what in their mind is good reason, sex sells. However it is creating an unrealistic image of the perfect female athlete, they are not judged by how good they are at hitting, catching, shooting, running or jumping, but by how much they can get paid for taking their clothes off. (Caple, Greenwood Lumby 2010) Another cause for concern over female sport is that professionally they are not getting anywhere near enough media coverage and money as their male counterparts. The media cover male sport in far more depth; in fact a study in 2006 by South Australian Premier’s Council for Women found just 4. per cent of coverage was about female sport () and on Foxtel approximately 10 per cent was about female sport (Senate Standing Committees on Environment, Communications and the Arts 2006). The chart below shows the volume of news coverage that all the different sports receive, which not surprisingly shows Tennis as being pretty much the main female sport that is being covered, with very little else in comparison to male sport, even horses gain more exposure than females. So while females are being splayed all over the magazines in compromising poses and clothing, they receive very little coverage of them competing within their sports. So even though the â€Å"Australian women’s swimming team at the 2004 Olympic games secured more medals than their male counterparts. The women’s hockey team, the Hockeyroos have frequently dominated international competition, winning Olympic gold and international championships on many occasions. The Australian women’s netball team has won eight of eleven world championships†(Senate Standing Committees on Environment, Communications and the Arts 2006), we still don’t see these teams play, other than at major sporting competitions like the Olympic and Commonwealth games. The lack of exposure can be hurtful to professional female athletes, in an interview with former Australian netball player explains her pain, â€Å"’I went very close to an emotional breakdown’ Ellis said, describing a time when she was struggling to combine her work as a solicitor, a marriage and the daily demands of club training and competing for Australia. (Magnay 2006) So while professional male sportsman have sport as their only profession earning a large salary in doing so, most women who compete at the top levels of their sports don’t actually receive any payment for their services, or if they do, they definitely couldn’t live of it, so majority of them have normal day jobs, which in itself would be stressful, but in conjunction with family, training and games, they must lead extremely demanding lives, which hardly seems reasonable. The inability of female sport to be fully professional and given similar or equal coverage in the media leaves the representation of women very much being subservient in a male dominated industry. The representation of the ultimate female ‘athlete’ projected as a result of the sexualisation that has occurred in higher level sport today has created a flow on effect into the amateur level of sport. Solmon et al. (2003) found that college-aged women who perceive a sport as gender-neutral are more confident about participating than are women who identify a sport as masculine. †(Hardin and Greer 2009, 207) Which is a direct result from media exposure, they see sports on television almost every day; recognize that it is a male sport as the athletes are male and then deem it too masculine to try. There is also the issue of sexuality discrimination when a female becomes involved with sport; because we see the masculine sports on television, any participation in such by a female has become deemed as homosexual, constructed by our culture and media, â€Å"so when a female is called a ‘dyke’ or ‘lesbian’ in a derogatory manner, she may alter her actions and dress to be ‘more feminine,’ downplay her athletic talents, or avoid sport altogether†(Schell n. d. ). This has become a common problem with women’s amateur sport, particularly sports that are deemed to be too masculine for women to try such as cricket (Burroughs, Seebohm and Ashburn 1995, 29) and Australian Rules football (Hillier 2006, 18) that there is an automatic stereotype of being homosexual. The social construction that female participants are labelled as homosexual in male dominated sports is a media formed fallacy. The reason why this has occurred is that in past societies, homosexuality was frowned upon and when a female athlete is found to be a lesbian, then the media reveals it to the world, the stereotype builds. This happened to the Australian women’s cricket team in the opposite fashion when â€Å"it was reported that female cricketer, Denise Annetts, had been dropped from the Australian team and had alleged that her sacking was due to her heterosexual preference and marital status. †( Burroughs, Seebohm and Ashburn 1995, 29) This built the reputation than women’s cricket still holds to this day. Nowadays there has been a movement towards helping women’s sport grow more. There have been the new Australian digital television channels which allowed channel Ten to show Netball during the day on their channel ‘One’. ABC still broadcast lawn bowls and women’s Basketball fairly often, and just this year, channel Nine started broadcasting female Twenty20 cricket that was played before the men’s game. So there has been improvement in the coverage regard, however women across the globe are still victims of sexploitation, which is undermining the coverage solution because we are still able to receive the media’s representation of females in sport as marginalised and subservient to a male industry. Until this is solved and females stand up against this, then there is little chance they have in improving their image in the sporting industry. Reference List Amateur Athletic Foundation of Los Angeles. 2000. Sportsletter. 12 (1,2): 2009. Quoted in Messner 2002, 100. Anna Kournikova. Image. 2000. http://sportsillustrated. cnn. com/vault/cover/toc/9744/index. htm (accessed May 20, 2011). Australia. Senate Standing Committees on Environment, Communications and the Arts. 2006. About time! Women in sport and recreation in Australia. Volume 1. Canberra: Senate Printing Unit. Burroughs, A. , L. Seebohm, and L. Ashburn. 1995. Sporting Traditions. The Journal of the Australian Society for Sports History 12 (1): 29. Google. www. google. om. au (accessed 21 May 2011). Caple, H. , K, Greenwood and C, Lumby. Image. 2010. http://www. ausport. gov. au/__data/assets/pdf_file/0007/356209/Towards_a_Level_Playing_Field_LR. pdf (accessed May 20, 2011) Carr, J. 2006. Maria Sharapova has become the sport’s most marketable icon. http://mariasharapova. wetpaint. com/page/Endorsements (accessed May 20, 2011). Eurosport. 2010. Australian Open – Cheeky Venus outfit shocks crowd. http://uk. eurosport. yahoo. com/24012010/58/australian-open-cheeky-venus-outfit-shocks-crowd. html (accessed May 23, 2011). Hardin, M. , J. D. Greer. 2009. The Influence of Gender-Role Socialization, Media Use and Sports Participation on Perceptions of Gender-Appropriate Sports. Journal of Sport Behavior 32 (2): 207. Questia. www. questia. com (accessed 19 May 2011). Hillier, L. 2006. Safe Spaces: The upside of the image problem for same sex attracted young women playing Australian Rules football. International Journal of Football Studies 8 (2): 18. Google. www. google. com. au (accessed 21 May 2011). Lingerie Football League. Image. 2009. http://www. stuff. co. nz/sport/2834471/New-Lingerie-Football-League-under-debate (accessed May 20, 2011). Magnay, J. 2006. Women deserve sporting chance: Ellis. http://www. smh. com. au/news/sport/women-deserve-sporting-chance-ellis/2006/08/02/1154198205721. html (accessed 20 May 2011). Maria Sharapova Bikini. Image. n. d. http://www. dailybum. com/ (accessed May 20, 2011). Messner, M. 2002. Taking the Field: Women, Men and Sports. Minneapolis: University of Minnesota Press. Schell, B. n. d. (Dis)Empowering Images? Media Representations of Women in Sport. http://www. womenssportsfoundation. org/Content/Articles/Issues/Media-and-Publicity/D/DisEmpowering-Images–Media-Representations-of-Women-in-Sport. aspx (accessed May 20, 2011). Short Research Essay Reflection What strengths and weaknesses did you identify in your Short Research Essay? My short research essay was not quite as good as what I had hoped, the topic Sexual Abuse in Sport: With a focus on the AFL was too narrow, it was not a smart decision to give myself such a small focus, which basically narrowed myself down to Australian texts only, which wasn’t easy. I did find a fair arrange of resources, but perhaps didn’t utilise them as much, and just relied on my own theory. The need to rely on stereotypes and overuse of emotive language also hampered my essay. How did you use the tutor’s feedback to improve your work for the Major Essay? I firstly acknowledged the fact that my essay used too much emotive language and made it a conscious focus to not try and use it so much, to what effect I am not sure, it is a habit in my writing that needs fixing for the future. I also rewrote my whole essay, broadening the topic to women in sport, which meant I could find an array of sources. I also have cleared up my analysis and hopefully the referencing has improved. All in all I believe that this essay is a far improvement on the short research essay.