Offer and acceptance of advance repudiation The WritePass Journal

Offer and acceptance of advance repudiation Introduction Offer and acceptance of advance repudiation Introduction1. The lapse of time:2.   Accepting the breach:Affirming the contractCharactersistics:Requirements:1. Legitimate interest:2. No cooperation:Risk to the non-breaching party following the decision to affirm after the other party’s anticipatory repudiation:ReferencesRelated Introduction Repudiation in the present sense occurs where a party indicates, either expressly or impliedly, by words or conduct that he does not intend to honor his obligations when they fall due in the future.(Richards, 2004) and (Furmston, 2006) p.688 It must be observed that, even if the party wrongfully repudiates all further liability, the contract will not automatically come to an end. Sinceits termination is the converse of its creation, principle demands that it should not be recognized unless this is what both party intend. The familiar test of offer and acceptance serves to determine their common intention. Where A and B are parties to an executor contract and A indicates that he is no longer able or willing to perform his outstanding obligations, he in effect makes an offer that the contract shall be discharged.(Furmston, 2006) Therefore B is presented with an option. He may either refuse or accept the offer as in Denmark Productions Ltd v Boscobel Productions Ltd[1]. More precisely, he may either affirm the contract by treating it as still in force or on the other hand he may treat it as finally and conclusively discharged. The consequences vary according to the choice that he prefers.(Furmston, 2006). Once the innocent party has elected to affirm or for that matter to treat the contract as discharged, he cannot retract his election. In Panchaud Frà ¨res SA v Établissements General Grain Co.[2] it was held that affirmation is really a species of waiver that results in an innocent party being stopped form alternating his election.(Richards, 2004) 1. The lapse of time: The injured party does have time to decide whether to affirm or terminate the contract but doing nothing for too long may be seen as affirmation as in the case StoczniaGdanska SA v Latvian Shipping[3]. (Koffman and Macdonald, 2004) The Court of Appeal recognized that there was a period prior to the election when the non-breaching party was making up its mind whether to terminate or affirm. In this period the contract and the right to terminate were both kept alive. As Rix LJ noted, this period cannot extend indefinitely and inaction over a sufficiently lengthy period may be held to constitute affirmation. In addition, since the contract remains alive until the non-breaching party terminates, the non-breaching party will be subject to the same risks that affect the non-breaching party who formally affirms. (Poole, 2008) 2.   Accepting the breach: An anticipatory breach of contract entitles the innocent party to terminate performance of the contract immediately. The novel feature of anticipatory breach is that acceptance of the breach entitles the innocent party to claim damages at the date of acceptance of the breach. He does not have to wait until the date fixed for performance, even though this has the effect of accelerating the obligations of the party in breach. It does seem illogical to say that a party can be in breach of contract before the time fixed for performance under the contract(McKendrick, 2009). The innocent party may choose to immediately terminate the contract and sue for damages even though the date for actual performance has not passed. This choice arises, it is said, because the other party has repudiated the contract by her actions.(Atiyah and Smith, 2006) Where the innocent party does decide to terminate performance of the contract he must give notice to the party in breach that he is accepting the anticipatory breach (or otherwise overtly evidence his acceptance of the breach) and he must not inconsistently with his decision to accept the breach (McKendrick, 2009). The innocent party has the right to elect to accept the repudiation as discharging the contract with the result that all his future obligations under the contract come to an end, as do the obligations of the guilty party, though here his obligation to pay damages arises by operation of law, as stated in Moschi v Lep Air Services Ltd.[4](Richards, 2004) There are, of course, dangers in treating an action by the other party as repudiation if it turns out to be viewed otherwise by the court. The party purporting to accept a repudiatory breach may well take action (as was the case in Vitol v Norelf) which itself involves a breach may find the tables turned and that that party itself is now liable to damages for its own breach of the contract. In Federal Commerce and Navigation Co Ltd v Molena Alpha Inc, the Nan Fir[5] which concerned the operation of three time charter parties, the charters deduct various amounts from the hire which they paid to the owners. The owners objected and issued instructions to the masters of a vessel concerned to withdraw all authority to the charters on their agents to sign the bills of lading. This action was held to amount to a repudiatory breach which entitled the charter to terminate the charter parties. (Stone, 2009) The innocent party must act so as to make plain that he claims to treat the contract as at an end. There is no reason why the acceptance of an anticipatory repudiation should not take the form of words or conducts which make it plain that the innocent party is responding to the repudiation by treating a contract as at an end. Thus, a failure to perform contractual obligations is capable of amounting to an acceptance of an anticipatory repudiation of a contract: Vitol S.A v Norelf Ltd; The Santa Clara[6]. The non-breaching party can sue at once, need not wait and if he does, he can win even though at the time of action his right is contingent, leading case is Frost v Knight 1872. (Upex et al., 2003) The most striking feature of the doctrine of anticipatory breach is that the acceptance of the breach entitles the victim to claim damages at one, before the time fixed for performance. This rule was established in Hochster v De La Tour. (Peel, 2007) Hochster v De La Tour[7] made it clear that damage can be claimed immediately on the basis of an accepted anticipatory breach without any need to wait for the time of performance. A similar result was reached in Frost v Knight[8]. In that case the defendant was promised the plaintiff that he would marry her when his father die. Subsequently the defendant broke off his engagement to the plaintiff. She took action while the defendant’s father was still alive and was successful in her claim. (Koffman and Macdonald, 2004) A leading case upon this subject is Hochster v De La Tour. The right to claim damages immediately exists even when the performance is not absolute as in Hochster v De La Tour but contingent as in Frost v Knight. In that case, performance was contingent upon an event which might not happen within the lifetime of the party.(Beatson, 2002) If the non-breaching party has terminated following the renunciation, it is clear that he can claim for damages from that time and does not need to wait until the date fixed for performance under the contract (Hochster v De La Tour). However, the non-breaching party would be under a duty to mitigate its loss as from the date of termination. In Reichman v Beveridge[9], a landlord and tenant case, the tenant argued that having left the premises three years into a five-year lease, there was a duty placed on the landlord to mitigate in a claim for rent arrears following the abandonment, e.g., by finding a replacement tenant, marketing the premises and not rejecting offers from prospective tenants. However, the Court of Appeal accepted that there was no such duty to mitigate in an action in debt (i.e., the action for arrears of rent).(Poole, 2008) Awarding damages for breach before performance is due may seem objectionable because where the interval between termination and the time of performance is long; an immediate damages award accelerates the defendant’s obligations and increases the potential for errors in quantifying damages since that conventionally rests on the market value of the lost performance at the time of performance. However, the rule can be justified for encouraging the speedy resolution of broken-down contracts and minimizing the claimant’s losses. It gives the claimant the incentive to terminate the contract immediately and move on, rather than keeping himself ready to perform (which is likely to increase his loss) a contract which will inevitably be breached come the time of performance.(Chen-Wishart, 2007) Affirming the contract Charactersistics: The non-breaching party can choose not to accept the repudiation, say by communicating that she is still expecting performance from the other party, then the contract remains in operation. In this case the innocent party can terminate or sue for damages if and when the breach actually happens, but in the meantime must remain ready to perform as required by the contract. This principle that the innocent party must remain able and willing to perform if he keeps the contract alive is, however, qualified by another principle, to the effect that if the guilty party continues to make it quite clear that he will not perform, the the innocent party can eventually abandon his attempts to perform. This can either be seen as an ultimate acceptance by conduct of the repudiation, after its initial rejection, or as an act of induced reliance by the innocent party, which stops the guilty party from complaining about the former’s inability to perform. (Atiyah and Smith, 2006) On the basis that the breach is repudiatory, the usual election will apply so that the non-breaching party will have the option of accepting the breach as terminating the contract, or affirming and awaiting performance on the contractual date set for that performance to begin (Fercometal SARL v Mediterranean Shipping Co. SA[10]).(Poole, 2008) In White Carter (Councils) Ltd v McGregor[11], the House of Lords (by a majority of 3:2) held that they were entitled to recover the contract price. There was no requirement that they minimize (or mitigate) their loss by finding an alternative business or product to advertise on the litterbins.(Poole, 2008) One of the reasons for the strict approach to identification of affirmation as requiring clear and unequivocal evidence of an intention to continue with the contract, is frequently stated to be that the election is irrevocable, i.e., having affirmed, the non-breaching party cannot change its mind in the period between affirmation and the contractual date for performance (although following non-performance on the contractual date there would be a new opportunity to elect to terminate or affirm for that actual repudiatory breach. As stated by Lord Ackner in Fercometal v Mediterranean Shipping: ‘there is no third choice to affirm the contract and yet be absolved from tendering further performance unless and until the breaching party gives reasonable notice that he is one again able and willing to perform’.(Poole, 2008) It has long been recognized that where the breach is continuing one (i.e., it continues after affirmation) and is repudiatory, the fact of the earlier affirmation will not prevent the non-breaching party form choosing to terminate in the period prior to that date set for contractual performance. This was recognized by Thomas J (obiter) in Stocznia Gdanska SA v Latvian Shipping Co[12].(Poole, 2008) If the injured party chooses not to accept the repudiation, then there is no breach at that point and no duty to mitigate. If the injured party can sue for the debt, he will not be concerned with the rules restricting recovery of damages, including the duty to mitigate. This can lead to the injured party claiming payment for an ‘unwanted and wasted’ performance, which contractors awkwardly with the mitigation rule’s limitation on recovery. The point arises from decision in White and Carter (Council) (Koffman and Macdonald, 2004). Where the innocent party does decide to affirm the contract and demand performance at the stipulated time, a number of consequences flow from this decision. The first is that affirmation does not prevent the innocent party accepting the breach if, at the date fixed for performance, the other party still refuses to perform. The second is that the innocent party, in addition to affirming the contract, may continue with the performance of his obligations under the contract, even though he knows that the performance is not wanted by that other party. This is what happened in the controversial case of White and Catter (McKendrick, 2009). Requirements: The principle laid down in White and Carter is, in fact, the subject of a number of qualifications. The first is that the innocent party cannot compel the party in breach to cooperate with him so that, where the innocent party cannot continue with performance without the cooperation of the party in breach, he will be compelled to accept the breach (Hounslow LBSC V Twickenham Ltd). The second qualification is derived from the speech of Lord Reid in White and Carter when he said that: ‘it may well be that, if it can be shown that a person has no legitimate interest, financial or otherwise, in performing the contract rather than claiming damages, he ought not to be allowed to saddle the other party with an additional burden with no benefit to himself.’ (McKendrick, 2009) 1. Legitimate interest: In view of the objections to wastage inherent in the White Carter principle, subsequent courts have seized upon statements by Lord Reid in order to limit the potential scope of the principle (indeed, Megarry J in Hounslow v Twickenham[13]).(Poole, 2008) Lord Reid said that the general power to affirm the contract could not be exercised by a person who had no ‘legitimate interest, financial or otherwise, in performing the contract rather than claiming damages’. However, it would be sufficient that it was merely ‘unreasonable’ to affirm; something more than this would be required.(Poole, 2008) Thus, the guilty party can avoid the operation of the principle in White Carter v McGregor by establishing that the non-breaching party has no legitimate interest in continuing performance.(Poole, 2008) Lord Reid’s statement was adopted and applied in Clea Shipping Corp. v Bulk Oil International Ltd, The Alaskan Trader[14]. The principle is clearly aimed at preventing very obvious wastage when the other party does not require performance. (Poole, 2008) 2. No cooperation: The second limitation requires that the affirming party must be able to continue with their own performance of the contract without the cooperation of the breaching party in order to be able to claim the contract price (otherwise the affirming party will be limited to a remedy in damages).(Poole, 2008) Cooperation in this context includes both active and passive cooperation of the renouncing party (e.g., Hounslow London Borough Council v Twickenham Garden Developments Ltd[15]: following renunciation by the local authority employers, contractors had no right to insist on continuing to perform the contract because the work was being done on local authority property and they were unable to gain access to the site without the local authority’s permission).(Poole, 2008) However, the restriction in White Carter that a claimant will be limited to a remedy in damages where he is unable to perform without the cooperation of the contract-breaker, applies only where the performance which has been prevented by the breach was a pre-condition to the payment obligation, i.e. the performance obligation was entire (in caseMinistry of Sound (Ireland) Ltd v World Online Ltd[16]) (Poole, 2008) Risk to the non-breaching party following the decision to affirm after the other party’s anticipatory repudiation: On the other hand, a decision to affirm the contract may work to the disadvantage of the innocent party. The first disadvantage is that an innocent party who affirms the contract may lose his right to sue for damages completely if the contract is frustrated between the date of the unaccepted anticipatory breach and the date fixed for performance (Avery v Bowden). Secondly, an innocent party who affirms the contract but subsequently breaches the contract himself cannot argue that the unaccepted anticipatory breach excused him from his obligation to perform under the contract. Where the breach is not accepted the parties remain subject to their obligation under the contract, so that the ‘innocent party’ may find himself liable to pay damages for breach of contract if he fails to accept the breach and subsequently breaches the contract himself (The Simona).(McKendrick, 2009) Following affirmation, the non-breaching party is exposed to a number of risks in the period between affirmation and remedies following the earlier renunciation. The existence of these risks lends support to the position adopted by the Court of Appeal in Stocznia since, if the non-breaching party does have to accept these risks, it is arguable that in this period the ability to terminate should continue to exist where the renunciation is continuing.(Poole, 2008) The risks placed on the affirming party in the period between affirmation and the date for performance are not insignificant. For example: 1.If the non breaching party is itself in breach of contract, that party cannot argue, at least not unless estoppels operates, that the initial renunciation by the other party operates as an excuse for its own subsequent breach as in Ferometal SARL v Mediterranean Shipping Co, SA, The Simona[1]. Once the contract was treated as being still in force, it was ‘kept alive for the benefit of both parties’, and the party affirming could not both keep it alive and seek to justify his own non-performance by reference to the earlier repudiation.(Poole, 2008) In a situation where there has been an anticipatory breach of contract the innocent party elects to affirm the contract, he is still required to perform his own obligations under the contract but faces the danger that, should he subsequently become guilty of a breach of contract, the other party may escape liability. This point was discussed in Ferometal SARL v Mediterranean Shipping Co, SA, The Simona.(Richards, 2004). 2.Similarly, if the contract is frustrated in the period between the affirmation and the due date for performance, the frustration will discharge the contract and the non-breaching party will lose the remedy of damages for the breach as in Avery v Bowden[2], the outbreak of Crimean War, thus depriving the ship-owners of a remedy they might have had for the failure to provide a cargo, hat that repudiation been accepted as terminating the contract.(Poole, 2008) A further danger with affirmation lies in the possibility that a frustrating event may occur after the innocent party has affirmed the contract. Where an innocent party has decided to affirm a contract and there is a breach when the date of performance on the contract arrives. References Atiyah, P. S. Smith, S. A. (2006), Introduction to the law of contract, 6th ed, Oxford: Oxford university press. Beatson, J. (2002), Law of contract, 28th ed, Oxford: Oxford University Press. Chen-Wishart, M. (2007), Contract law, 2nd ed, Oxford: Oxford University Press. Furmston, M. (2006), Cheshire, Fifoot and Furmstons law of contract, 15th ed, Oxford: Oxford University Press. Koffman, L. Macdonald, E. (2004), The law of contract, 5th ed, London: Tolley. Mckendrick, E. (2009), Contract law, 8th ed, Basingstoke: Palgrave Macmillan. Peel, E. (2007), Treitel, The law of contract, 12th ed, London: Sweet Maxwell. Poole, J. (2008), Textbook on contract law, 9th ed, Oxford: Oxford University. Richards, P. (2004), Law of contract, 6th ed, Harlow: Pearson Longman. Stone, R. (2009), The modern law of contract, 8th ed, London: Routledge-Cavendish. Upex, R., Bennet, G. Chuah, J. (2003), Davies on contract, 9th ed, London: Sweet Maxwell.

Biography of Martin Luther King, Jr.

Biography of Martin Luther King, Jr. Martin Luther King, Jr. was born on January 15, 1929, in Atlanta, GA. His birth certificate listed his first name as Michael, but this was later changed to Martin. His Grandfather and then his Father both served as the pastor of the Ebenezer Baptist Church in Atlanta, Georgia. King graduated from Morehouse College in 1948 with a degree in Sociology. He further received a Bachelors of Divinity in 1951 and then a Ph.D. from Boston College in 1955. It was in Boston where he met and later married Coretta Scott. They had two sons and two daughters together. Becoming a Civil Rights Leader: Martin Luther King, Jr. was appointed the pastor of the Dexter Avenue Baptist Church in Montgomery, Alabama in 1954. It was while serving as pastor of the church that Rosa Parks was arrested for refusing to give up her seat on a bus to a white man. This occurred on December 1, 1955. By December 5, 1955, the Montgomery Bus Boycott had begun. Montgomery Bus Boycott: On December 5, 1955, Dr. Martin Luther King, Jr. was unanimously elected president of the Montgomery Improvement Association which led the Montgomery Bus Boycott. During this time, African-Americans refused to ride the public bus system in Montgomery. Kings home was bombed due to his involvement. Thankfully his wife and baby daughter who were home at the time were unharmed. King was then arrested in February on the charges of conspiracy. The boycott lasted 382 days. At the end on December 21, 1956, the Supreme Court ruled that racial segregation on public transportation was illegal. Southern Christian Leadership Conference: The Southern Christian Leadership Conference (SCLC) was formed in 1957 and King was named its leader. Its goal was to provide leadership and organization in the fight for civil rights. He used the ideas of civil disobedience and peaceful protests based on the writings of Thoreau and the actions of Mohandas Gandhi to lead the organization and the fight against segregation and discrimination. Their demonstrations and activism helped lead to the passage of the Civil Rights Act of 1964 and the Voting Rights Act of 1965. Letter from a Birmingham Jail: Dr. Martin Luther King, Jr. was a major part of many nonviolent protests as he helped lead the fight for desegregation and equal rights. He was arrested numerous times. In 1963, numerous sit-ins were staged in Birmingham, Alabama to protest segregation in restaurants and eating facilities. King was arrested during one of these and while he was imprisoned wrote his famous Letter from a Birmingham Jail. In this letter, he argued that only through visible protests would progress be made. He argued that it was an individuals duty to protest and disobey unjust  laws. Martin Luther King's "I Have a Dream" Speech On August 28, 1963, the March on Washington led by King and other Civil Rights Leaders took place. It was the largest demonstration of its kind in Washington, D.C. up to that time and approximately 250,000 demonstrators were involved. It was during this March that King gave his awe-inspiring I Have a Dream speech while speaking from the Lincoln Memorial. He and the other leaders then met with President John F. Kennedy. They asked for many things including an end to segregation in public schools, greater protections for African-Americans, and more effective civil rights legislation amongst other things. Nobel Peace Prize In 1963, King was named Time Magazines Man of the Year. He had stepped onto the world stage. He met with Pope Paul VI in 1964 and then was honored as the youngest person ever to receive the Nobel Peace Prize. He was awarded this on December 10, 1964, at the age of thirty-five. He gave the entire amount of the prize money to help with the Civil Rights movement. Selma, Alabama On March 7, 1965, a group of protestors attempted a march from Selma, Alabama to Montgomery. King was not part of this march because he had wanted to delay its start date until the 8th. However, the march was extremely important because it was met by terrible police brutality that was captured on film. The images of this made a huge impact on those not directly involved in the fight resulting in a public outcry for changes to be made. The March was attempted again, and the protestors successfully made it to Montgomery on March 25, 1965, where they heard King speak at the Capitol. Assassination Between 1965 and 1968, King continued with his protest work and fought for Civil Rights. King became a critic of the War in Vietnam. While speaking from a balcony at the Lorraine Motel in Memphis, Tennessee on April 4, 1968, Martin Luther King was assassinated. The day before he gave a poignant speech where he said, [Gods] allowed me to go up to the mountain. And Ive looked over. And Ive seen the promised land. I may not get there with you. While James Earl Ray was arrested and charged with the assassination, there have been and still are questions to his guilt and whether there was a larger conspiracy at work.

Strategic Management Essay Example | Topics and Well Written Essays - 1500 words - 2

Strategic Management - Essay Example Apart from the tangible benefits in terms of financial loss, the firm also faced huge crisis in terms of losing intangible losses such as that of skills and experiences. Along with these losses, the firm also faced problem that was in the form of diversion of attention from better opportunities for avoiding risk. The decision of selling out the unprofitable business units was generated as renovating plans for the 21st century. Fundamentally, four aims were set for this era that included the following: (a) reduction of operational holdings that failed to either achieve the short-term goals or are not fit for the firms long-term sustainable strategy and a targeted profit of 600 to 700 million Dollars was anticipated from their sales; (b) reinvestment of the accumulated profits from these sales to profitable business areas of the firm; (c) improvement of equity return from these reinvesting strategies in the long run; and (d) strengthening of the firm’s financial position in term s of reviewing balance sheet and position of credit. The firm followed the benchmarking technique with the help of BCG matrix utilization and derived that the structure of the firm would be designed as such that it would be comprising of mainly four business units: financial services, energy, packaging and forest products. Following the designed strategies, the firm insisted on selling the unprofitable business units but in this case also the firm faced the same problem of being unable to achieve strategic targets. It failed to generate the targeted 700 million Dollars sales from those units and achieved a figure which was around 250 million Dollars lesser than that was targeted. Prior to providing recommendation based on the analysis of the current situation of the firm in the form of a strategic plan of five years, it is essential to present a brief outlook of each of the positions of business units or the exact situation that the firm at present is facing. Lockwood Group’s financial services unit is believed to be strongly positioned within the industry. It is due to the efficiency of the management that this business unit has become able to enhance their targeted segment of the market and also have become successful in avoiding any grave situation of cut throat competition with huge and potent competitors. Avoidance of competitors was essential for the business units holding a brand new position within the industry. With regard to the business position of energy, the firm is in a strong position in spite of being an initial operator within the industry but taking into account the firm’s abilities in production and exploration of energy, its position is not that strong. The unit of production and exploration is believed to be at a risky position as the firm does not hold strong position of investing huge amounts of money in exploration activities and also are reluctant in taking risk through exploring in adverse situations. In the packaging se gment of the firm’s business, it is holding an uncertain position as in order to become successful in this segment, the firm would have to remain updated along with the

Why is social integration such a problem for immigrants in France Essay

Why is social integration such a problem for immigrants in France - Essay Example (Essess, Dovidio, Dion. 375). European countries faced a large number of migrations after world war-II. The integration of the immigrants is the new challenge for the established states. The countries faced the challenges and struggled with the problem of inclusion of the immigrants in to their social structure. There has been enormous increase in movement of international population with world migration. This is characterized by not only by increased levels of permanent settlement and labor in foreign countries but also temporary migration with varying purpose. The integration of the immigrants, the inclusion of population in the existing social structure of the immigration country is one of the concerns of the state policies and structure. There are four major dimensions, which differentiated the process of integration. The first one is the structure integration, which is the acquisition of rights and access to membership and position to the society. The education system, labor market, housing and citizenship are major factor affects structural integration. The second dimension is cultural integration, which is a precondition of participation and refers to process of cognitive, cultural, behavioral and attitudinal change of persons. The third one is Social integration. The social integration is reflected in the relationship with society and group members. The social intercourse, friendship, marriage and involvement in voluntary association are the part of social integration. Social identification is the fourth dimension. The nationality, ethnics and other forms of multiple and social identification reflect in the membership to a new society. Like other countries in Europe France is also face the increasing of immigration. The European integration and opening up of the internal border of countries within Europe cause the increase in migration in France. The major risk affected by the opening up of borders is immigration, drug trafficking and international crime. The France has had a long history of receiving and encouraging the immigrants. The different goal of immigration is forced by labor needs and population replacement. Between 1850 and 1913 the number of immigrants entering France increase from 3,80,000 to 1.6 million. In this period immigration is encouraged by industrialization in France. Following World War-I the shortage of labor due to military causalities expanding industries welcomes the immigrants to France. During 1921 to 1931 the immigrants' population is increased to 2.7 million, from the major parts of China, Vietnam and different parts of Asia and Africa. The end of World War-II the Government introduce d the centrally controlled policy favoring migration. The Office of National del' Immigration (ONI) was established in 1945 and its regulated residence and employment of foreigners in the country. (James, Rita. 147). In 1974 the government tightened the policy on immigrants and stopped labor immigrants and temporary workers and given preference to the relatives of migrants. In 1984 the French Government rejected one third of migration request from different part of the world. From 1990 onwards the Government rejected 71 to 84 percent of asylum seekers to France. (Heckmann, Schnapper. 16) Issues for Immigrants The France is a country with long history of immigration and there is tradition called 'assimilation

Cultural Considerations Essay Example for Free

Cultural Considerations Essay People belonging to different cultures have different perception towards the aspects of life and justice is also under these aspects that have significant impact of culture. Individuals belonging to particular cultures have their opinion about the justice that is greatly influenced by the type of culture they belong to as every culture has some ethics and values that each individual and society follows. The concept of globalization has made people to live in diverse countries with different justice system and this leads to the issue of cross cultural disparity in perception of justice of different systems. So the culture values play a significant role in perceptions of justice and outcomes along with the comparison process (Bond, 1982). Since the people associated with certain cultures have their own beliefs and these beliefs of individuals belonging to different cultures contradicts them with the laws and regulations of a particular country. Some cultural facets negate or mitigate criminal responsibility where acts are committed under a reasonable good-faith belief in their propriety, based on the individual’s cultural heritage or tradition and this makes the people of particular culture to disagree with justice formulation of culture. The dissatisfaction of people from the justice system of the country escorts practical problems of the law and culture clash in the context of criminal and to some degree to civil liabilities also. These differences also cause variety of cases including homicide, the treatment of children, animals and the dead as well as the regulation of marriage, attire, and drug usage cases to rise to a greater extent thus making it difficult for the security administration to enforce proper law and order (Bond, 1982). The ethics and values of a particular culture impose serious problems for the security administrations also as people commit crimes and associate their sins particularly with criminal defenses, civil rights, and cultural regulations. So it became very difficult for the administration to regulate the country with different cultures as people take the shelter of their respective cultures in order to avoid serious punishments. This also makes the whole system reluctant of imposing the better regime along with the law-culture clash that raises questions of hegemonic domination, human rights and political philosophy in the whole country. It is very difficult for the administration to maintain the justice right for all the individuals believing in different cultures as they have dissimilar issues so the governments of countries with mixed cultures have adopted services that can solve the law-culture issues. One of the most commonly followed policies is the Community Relation Service as it provides platform to solve various issues based on race, color or culture. The countries have adopted qualitative dimensions with respect to justice in order to gather community perspectives at each stage of the justice process, while a quantitative dimension provides the opportunity to demonstrate outcomes that have credibility for community members and scholars also. Transformative mixed methodologies are also used by modern day systems to provide a mechanism for addressing the complexities of system coordination in culturally complex settings that can provide a basis for social stability (Kymlicka, 1995). Countries also use other methods like change in demographics and immigrant patterns to avoid clashes and these countries also set values under the justification and made immigrants aware of their laws in order to make every one aware of the law and regulation configuration (Kymlicka, 1995). These policies help the justice administration to put their decisions in the perfect manner so that the law and order of the society is maintained without any sort of fuss among the masses. The security administration also provides better policing facilities to provide enhanced level of security among the common people and avoid incidents that can lead to violence. The factors leading to the crime are also considered by most of the systems so that convicted individual is awarded punishment by considering all the parameters. These policies and methods provide a better coordination between the administration and the people belonging to different cultures by considering the issues and beliefs of particular culture and judging the individuals accordingly to provide most levelheaded and well composed justice. In 1829, Sir Robert Peel created the Metropolitan Police when he served as Home Secretary of England. According to Peel, the real key for policing is the police are the people and the people are the police. His principles can still be used in the present era as the prevention of crime should be the main idea in order to maintain a peaceful environment all over the state. The public approval could also be used like his principles as in case of diverse society, it is necessary for police to understand the different cultures that make up the communities that they patrol. This can be accomplished through multi-cultural training and education so that there is no problem in tackling the issues that involved people from different cultural background.

William Harrison :: essays research papers fc

William Henry Harrison William Harrison was our 9th president. He had many accomplishments before he was president. He gave the longest inaugural speech. In 1809 William Harrison negotiated the Treaty of Fort Wayne. The treaty was an agreement between the United States and many Native American tribes. In 1811 Harrison led soldiers in the battle of Tippecanoe against a Shawnee Tribe. The Americans won the battle and he was a hero after the Battle of Tippecanoe. He was also in charge of the committee on military affairs. In 1816 he was elected to the U.S. House of Representatives. In 1819 he was elected to the Ohio State Senate. In 1825 he was elected to the U.S. Senate. He then was named minister of a South American country called Columbia. Later he became governor of Indian Lands. In 1836 he lost the election for president to Martin Van Buren. Then he won the next election in 1840.William Harrison had a lot of accomplishment before he was president. William Harrison was born in Virginia. He had to over come some obstacles in his life. One was he grew up during the American Revolution. He and His father disagreed about the job Harrison would have. His father wanted him to be a doctor but when he died Harrison stopped studying medicine and joined the army. He also fought in a lot of difficult battles against the British and the Native Americans. Six out of ten of William Harrison’s children died at an early age. He overcame all of these obstacles. William Harrison only was in office for one month. This was because he caught pneumonia and died.

Cancer Fighting Diet

[pic] This Article has been added to your favorites. View your profile [pic]Cancer Diet AdsProstate CancerFighting Lung CancerColon Cancer SignsHealth Diet FoodPreventing Cancer [pic] Beets are protective against cancers of the skin, lung and colon. Cancer is the second leading cause of death in the United States today. While the link between diet and cancer remains somewhat elusive, there are specific dietary factors tied to a reduction in cancer development. Foods that are high in fiber, nutrient-dense and antioxidant-rich offer the most protection against cancer development. According to the American Cancer Society, foods that offer the most benefits include legumes, cruciferous and green leafy vegetables, whole fresh fruits (especially red and citrus fruits) and foods high in omega-3-fats. Broccoli Broccoli is an example of a cruciferous vegetable. Others within the same family include cabbage, onions, garlic and cauliflower. They are rich in phytonutrients, or disease-fighting plant compounds that directly inhibit the growth of cancer cells and the development of tumors. 2. Salmon Fatty fish, such as salmon, is rich in vitamin D–which offers protection against the development of certain types of cancers, including colon cancer–and omega 3 fats. Omega 3 fats act as anti-tumor agents because they help prevent cancer cells from sticking together, forming solid tumors. Oranges and Citrus Fruits Citrus fruits are an excellent source of vitamin C. Vitamin C protects the body's cells against free radical damage, which can cause damage to DNA (mutations) that increases the risk of cancer development, especially of the digestive system and colon. Blueberries The nutrients found in blueberries may help reduce the risk of developing colon and ovarian cancer. Phenolic compounds (another phytochemical found in blue/purple vegetables and fruits) inhibit the rapid growth of cancer cells and work to destroy cancer cells in the colon. Spinach and Kale Dark, leafy, green vegetables such as spinach and kale are rich in a flavonoid phytonutrient called kaempferol. Women who eat the most kaempferol-rich foods have a 40 percent lower risk of developing ovarian cancer than those that with the lowest intake of kaempferol-rich foods. Raspberries Raspberries are the richest food source of ellagic acid. Ellagic acid is a phytochemical that offers powerful anti-cancer benefits according to the American Cancer Society. It can inhibit cancerous tumor growth in the esophagus, lung and colon as well as the breast and prostate. Pomegranate Juice Recent findings by the American Cancer Society also show that drinking 8 oz. of pomegranate juice daily significantly slows increase of blood levels of prostate-specific antigen, or PSA, which is the marker used to test for prostate cancer as well as measuring the growth of prostate cancer. Black Beans According to a study published in Food Chemistry and Toxicology, when researchers fed laboratory animals a 20 percent black bean diet, it significantly reduced the number of pre-cancerous cells, even in animals who were also given an agent that promotes cancer by mutating cellular DNA (cyclophosphamide). Green Tea Green tea is high health-promoting flavonoids, including catechins. The most notable catechin in green tea is epigallocatechin-3-gallate (EGCG). EGCG offers anticancer and antioxidant benefits. Like vitamins E and C, catechins act as free radical scavengers and are particularly protective against breast and prostate cancers. Beets The pigment that gives beets their purple-deep red color is known as betacyanin. This phytochemical acts as a powerful cancer-fighting agent, particularly against the development of cancers of the skin, lung and colon. Compounds in beets increase the effectiveness of antioxidant liver enzymes which help protect our cells against free radical damage. [pic]Sponsored Links Advanced Cancer Treatment Cancer Treatment Options as of March 2010 www. Issels. com Which Foods Burn Fat? The eating program preferred by bodybuilders and fitness models www. burnthefat. com Lose Weight w/ Green Tea Lose 2. times more with Wu Long tea. Buy 3, get 1 free! 2xGreen. WuLongForLife. com Stem Cell Therapy Germany Lower fasting glucose levels Decrease hypoglycemic events www. XCell-Center. com/Diabetes/ References †¢ â€Å"Dietary factors and cancer chemoprevention: an overview of obesity-related malignancies;† N. S. Murthy, S. Mukherjee, G. Ray, et al; 2009 †¢ â€Å"Food Chemistry a nd Toxicology;† Black bean (Phaseolus vulgaris L. ) as a protective agent against DNA damage in mice; L. Azevedo, J. C. Gomes, P. C. Stringheta, A. M. Gontijo, C. R. Padovani, L. R. Ribeiro and D. M. Salvadori; Dec 2003 †¢ â€Å"Cancer Letters;† Chemoprevention of lung and skin cancer by Beta vulgaris (beet) root extract; G. J. Kapadia, H. Tokuda, T. Konoshima and H. Nishino; Feb 1996 The Anti-Cancer Diet Cancer Prevention Nutrition Tips and Cancer Fighting Foods [pic][pic] [pic] Are you interested in doing all you can to improve your health and fight off cancer? Maybe you have a history of cancer in your family or a loved one who’s battling the disease. Maybe you’re dealing with cancer yourself or trying to prevent a recurrence. Whatever the situation, your dietary choices matter. Some foods actually increase your risk of cancer, while others support your body and strengthen your immune system. By making smart food choices, you can protect your health, feel better, and boost your ability fight off disease. In This Article: †¢ What you need to know †¢ Focus on plant-based foods †¢ Bulk up on fiber †¢ Cut down on meat †¢ Choose your fats wisely †¢ Choose cancer-fighting foods †¢ Prepare your food in healthy ways †¢ Related links [pic]Print   [pic]Authors [pic][pic][pic]Text Size What you need to know about cancer and diet Not all health problems are avoidable, but you have more control over your health than you may think. Research shows that a large percentage of cancer-related deaths—maybe even the majority—are directly linked to lifestyle choices such as smoking, drinking, a lack of exercise, and an unhealthy diet. Avoiding cigarettes, minimizing alcohol, and getting regular exercise are a great start to an anti-cancer lifestyle. But to best support your health, you also need to look at your eating habits. What you eat—and don’t eat—has a powerful effect on your health, including your risk of cancer. Without knowing it, you may be eating many foods that fuel cancer, while neglecting the powerful foods and nutrients that can protect you. If you change your diet and behaviors, you can minimize your risk of disease and possibly even stop cancer in its tracks. Cancer prevention diet tip #1 – Focus on plant-based foods Why plant-based foods are cancer-fighting powerhouses It comes down to this: Plants have less fat, more fiber, and more cancer-fighting nutrients. These three elements work together to support your immune system and help your body fight off cancer. The best diet for preventing or fighting cancer is a predominantly plant-based diet that includes a variety of vegetables, fruits, and whole grains. A plant-based diet means eating mostly foods that come from plants: vegetables, fruits, nuts, grains, and beans. The less processed these foods are—the less they’ve been cooked, peeled, mixed with other ingredients, stripped of their nutrients, or otherwise altered from the way they cam out of the ground—the better. There are many ways to add plant-based foods to your diet. A nice visual reminder is to aim for a plate of food that is filled at least two-thirds with whole grains, vegetables, beans, or fruit. Dairy products, fish, and meat should take up no more than a third of the plate. Keep in mind that you don’t need to go completely vegetarian. Instead, focus on adding â€Å"whole† foods, which are foods close to their original form. Just as important, try to minimize or reduce the amount of processed foods you eat. Eat an apple instead of drinking a glass of apple juice, for example. Or enjoy a bowl of oatmeal with raisins instead of an oatmeal raisin cookie. Simple tips for getting more plant-based foods in your diet †¢ Breakfast: Add fruit and a few seeds or nuts to your whole grain breakfast cereal (oatmeal! ). †¢ Lunch: Eat a big salad filled with your favorite beans and peas or other combo of veggies. Always order lettuce and tomato (plus any other veggies you can! ) on your sandwiches. Order whole grain bread for your sandwiches. Have a side of veggies like cut up carrots, sauerkraut or a piece of fruit. †¢ Snacks: fresh fruit and vegetables. Grab an apple or banana on your way out the door. Raw veggies such as carrots, celery, cucumbers, jicama, peppers, etc. are great with a low-fat dip such as hummus. Keep trail mix made with nuts, seeds and a little dried fruit on hand. †¢ Dinner: Add fresh or frozen veggies to your favorite pasta sauce or rice dish. Top a baked potato with broccoli and yogurt, sauteed veggies, or with salsa. Replace creamy pasta sauces, with sauteed vegetables or tomato sauce made with healthy olive oil. †¢ Dessert: Choose fruit instead of a richer dessert. Or a single square of dark chocolate. Buy organic or local produce, if possible. Some pesticides found in commercially-grown produce are also suspected carcinogens. Organic foods are free of these pesticides, and locally grown produce is less likely to have been treated with chemicals to prevent spoilage. Cancer prevention diet tip #2 – Bulk up on fiber Another benefit of eating plant-based foods is that it will also increase your fiber intake. Fiber, also called roughage or bulk, is the part of plants (grains, fruits, and vegetables) that your body can’t digest. Fiber plays a key role in keeping your digestive system clean and healthy. It helps keep food moving through your digestive tract, and it also moves cancer-causing compounds out before they can create harm. Fiber is found in fruits, vegetables, and whole grains. In general, the more natural and unprocessed the food, the higher it is in fiber. There is no fiber in meat, dairy, sugar, or â€Å"white† foods like white bread, white rice, and pastries. Simple ways to add more fiber to your diet: †¢ Use brown rice instead of white rice †¢ Substitute whole-grain bread for white bread †¢ Choose a bran muffin over a croissant or pastry †¢ Snack on popcorn instead of potato chips †¢ Eat fresh fruit such as a pear, a banana, or an apple (with the skin) †¢ Have a baked potato, including the skin, instead of mashed potatoes †¢ Enjoy fresh carrots, celery, or bell peppers with a hummus or salsa, instead of chips and a sour cream dip †¢ Use beans instead of ground meat in chili, casseroles, tacos, and even burgers (bean burgers taste great! |High-fiber, cancer-fighting foods | |Whole grains |whole-wheat pasta, raisin bran, barley, oatmeal, oat bran muffins, popcorn, brown rice, whole-grain | | |or whole-wheat bread | |Fruit |raspberries, apples, pears, strawberries, bananas, lackberries, blueberries, mango, apricots, | | |citrus fruits, dried fruit, prunes, raisins | |Legumes |lentils, black beans, s plit peas, lima beans, baked beans, kidney beans, pinto, chick peas, navy | | |beans, black-eyed peas | |Vegetables |broccoli, spinach, dark green leafy vegetables, peas, artichokes, corn, carrots, tomatoes, Brussels | | |sprouts, potatoes | Cancer prevention diet tip #3: Cut down on meat Research shows that vegetarians are about fifty percent less likely to develop cancer than those who eat meat. So what’s the link between meat and cancer risk? First, meat lacks fiber and other nutrients that have been shown to have cancer-protective properties. What it does have in abundance, however, is fat—often very high levels of saturated fat. High-fat diets have been linked to higher rates of cancer. And saturated fat is particularly dangerous. Finally, depending on how it is prepared, meat can develop carcinogenic compounds. Making better meat and protein choices You don’t need to cut out meat completely and become a vegetarian. But most people consume far more meat than is healthy. You can cut down your cancer risk substantially by reducing the amount of animal-based products you eat and by choosing healthier meats. †¢ Keep meat to a minimum. Try to keep the total amount of meat in your diet to no more than fifteen percent of your total calories. Ten percent is even better. †¢ Eat red meat only occasionally. Red meat is high in saturated fat, so eat it sparingly. †¢ Reduce the portion size of meat in each meal. The portion should be able to fit in the palm of your hand. †¢ Use meat as a flavoring or a side, not the entree. You can use a little bit of meat to add flavor or texture to your food, rather than using it as the main element. †¢ Add beans and other plant-based protein sources to your meals. †¢ Choose leaner meats, such as fish, chicken, or turkey. If possible, buy organic. †¢ Avoid processed meats such as hotdogs, sausage, deli meats, and salami. Cancer prevention diet tip #4: Choose your fats wisely A major benefit of cutting down on the amount of meat you eat is that you will automatically cut out a lot of unhealthy fat. Eating a diet high in fat increases your risk for many types of cancer. But cutting out fat entirely isn’t the answer, either. In fact, some types of fat may actually protect against cancer. The trick is to choose your fats wisely and eat them in moderation. †¢ Fats that increase cancer risk – The two most damaging fats are saturated fats and trans fats. Saturated fats are found mainly in animal products such as red meat, whole milk dairy products, and eggs. Trans fats, also called partially hydrogenated oils, are created by adding hydrogen to liquid vegetable oils to make them more solid and less likely to spoil—which is very good for food manufacturers, and very bad for you. †¢ Fats that decrease cancer risk – The best fats are unsaturated fats, which come from plant sources and are liquid at room temperature. Primary sources include olive oil, canola oil, nuts, and avocados. Also focus on omega-3 fatty acids, which fight inflammation and support brain and heart health. Good sources include salmon, tuna, and flaxseeds. Tips for choosing cancer-fighting fats and avoiding the bad †¢ Reduce your consumption of red meat, whole milk, butter, and eggs, as these are the primary source of saturated fats. †¢ Cook with olive oil instead of regular vegetable oil. Canola oil is another good choice, especially for baking. †¢ Check the ingredient list on food labels and avoid anything with hydrogenated or partially hydrogenated oils, which are usually found in stick margarines, shortenings, salad dressings, and other packaged foods. Trim the fat off of meat when you do eat it, and avoid eating the skin of the chicken. †¢ Choose nonfat dairy products and eggs that have been fortified with omega-3 fatty acids. †¢ Add nuts and seeds to cereal, salads, soups, or other dishes. Good choices include walnuts, almonds, pumpkin seeds, hazelnuts, pecans, and sesame seeds. †¢ Use flaxseed oil in smoothies, salad dressings, or mixed in snacks such as applesauce. But do not cook with flaxseed oil, as it loses its protective properties when heated. †¢ Limit fast food, fried foods, and packaged foods, which tend to be high in trans fats. This includes foods like potato chips, cookies, crackers, French fries, and doughnuts. †¢ Eat fish once or twice a week. Good choices include wild Alaskan salmon, sardines, herring, and black cod. But be conscious of mercury, a contaminant found in many types of fish. Making smart seafood choices For a list of the best and worst seafood choices, see the Pocket Seafood Selector, from the Environmental Defense Food. Cancer prevention diet tip #5: Choose cancer-fighting foods Your immune system keeps you healthy by fighting off unwanted invaders in your system, including cancer cells. There are many things you can eat to maximize the strength of your immune system, as well as many cancer-fighting foods. But keep in mind that there is no single miracle food or ingredient that will protect you against cancer. Eating a colorful variety gives you the best protection. †¢ Boost your antioxidants. Antioxidants are powerful vitamins that protect against cancer and help the cells in your body function optimally. Fruits and vegetables are the best sources of antioxidants such as beta-carotene, vitamin C, vitamin E, and selenium. †¢ Eat a wide range of brightly colored fruits and vegetables. Colorful fruits and vegetables are rich in phytochemicals, a potent disease–fighting and immune–boosting nutrient. The greater the variety of colors that you include, the more you will benefit, since different colors are rich in different phytochemicals. †¢ Flavor with immune-boosting spices and foods. Garlic, ginger, and curry powder not only add flavor, but they add a cancer-fighting punch of valuable nutrients. Other good choices include turmeric, basil, rosemary, and coriander. Use them in soups, salads, casseroles, or any other dish. †¢ Drink plenty of water. Water is essentially to all bodily processes. It stimulates the immune system, removes waste and toxins, and transports nutrients to all of your organs. Cancer prevention diet tip #6 – Prepare your food in healthy ways Choosing healthy food is not the only important factor. It also matters how you prepare and store your food. The way you cook your food can either help or hurt your anti-cancer efforts. Preserving the cancer-fighting benefits of vegetables Here are a few tips that will help you get the most benefits from eating all those great cancer-fighting vegetables: †¢ Eat at least some raw fruits and vegetables. These have the highest amounts of vitamins and minerals, although cooking some vegetables can make the vitamins more available for our body to use. †¢ When cooking vegetables, steam until just tender using a small amount of water. This preserves more of the vitamins. Overcooking vegetables leaches the vitamins and minerals out. For an extra vitamin boost, use the vegetable cooking water in a soup or another dish. †¢ Wash or peel all fruits and vegetables. Use a vegetable brush for washing. Washing does not eliminate all pesticide residue, but will reduce it. Cooking and carcinogens Carcinogens are cancer-causing substances found in food. Carcinogens can form during the cooking or preserving process—mostly in relation to meat—and as foods start to spoil. Examples of foods that have carcinogens are cured, dried, and preserved meats (e. g. bacon, sausage, beef jerkey); burned or charred meets; smoked foods; and foods that have become moldy. Here are some ways reduce your exposure to carcinogens: The 5 Worst Foods to Grill o Chicken breast, skinless, boneless, grilled, well done o Steak, grilled, well done o Pork, barbecued o Salmon, grilled with skin o Hamburger, grilled, well done Source: Physicians Committee for Responsible Medicine Do not cook oils on high heat. Low-heat cooking or baking (less than 240 degrees) prevents oils or fats from turning carcinogenic. Instead of deep-frying, pan-frying, and sauteing, opt for healthier methods such as baking, boiling, steaming, or broiling. †¢ Go easy on the barbecue. Burning or charring meats creates carcinogenic substances. If you do choose to barbecue, don’t overcook the meat and be sure to cook at the proper temperature (not too hot! ). †¢ Store oils in a cool dark place in airtight containers, as they quickly become rancid when exposed to heat, light, and air. †¢ Choose fresh meats instead of cured, dried, preserved, or smoked meats. †¢ Avoid foods that look or smell moldy, as they likely contain aflatoxin, a strong carcinogen. Aflatoxin is most commonly found on moldy peanuts. Nuts will stay fresh longer if kept in the refrigerator or freezer. Be careful what you put in the microwave. Use waxed paper rather than plastic wrap to cover your food in the microwave. And always use microwave-safe containers. Related articles [pic]Organic Foods Understanding Organic Food L abels, Benefits, and Claims [pic]Healthy Recipes Making Fast, Healthy, and Delicious Meals More Helpguide Articles: †¢ Healthy Eating: Easy Tips for Planning a Healthy Diet and Sticking to It †¢ Healthy Fast Food: Tips for Making Healthier Fast Food Choices †¢ Dietary Supplements: The Smart and Safe Use of Vitamins and Supplements Related links for cancer prevention and the anti-cancer diet The Cancer Prevention Diet Cancer Prevention – This article talks about the relationship between human behaviors such as diet and cancer. (National Cancer Institute) The Anti-cancer Diet – This article gives very detailed information on 12 dietary recommendations that lower your cancer risk. (Ask Dr. Sears) Cancer Prevention: Ask the Expert: Nutrition – Brief answers to some common questions about the relationship between diet and cancer. (Michigan State University) Foods for Cancer Prevention – A brief summary of what cancer is, plus what dietary choices help to reduce your risk of cancer. (PCRM) Foods that Fight Cancer – Information on specific foods and their role in protecting your health. AICR) Fiber 101: Soluble Fiber vs. Insoluble Fiber – A summary about why eating fiber is important, as well as the difference between soluble and insoluble fiber, plus examples of fiber rich foods. (HealthCastle. com) Cancer Facts: Meat Consumption and Cancer Risk – Inform ation on the relationship between eating meat and how that affects your risk for cancer. (The Cancer Project) Cooking to Prevent Cancer Cut Calories & Fat, Not Flavor – Recommendations for how to reduce your fat intake when cooking while still maintaining flavor. (American Cancer Society) Going Low-Fat: Low-Fat Cooking Methods – This article is filled with tips on how to cook tasty low-fat meals. NutritionMD) Cancer Prevention and Immune System Strengthening Immune Function: Choose Immune-Boosting Foods – This article has information on immune boosting foods and includes recipes as well as information on specific nutrients. (NutritionMD) Maya W. Paul and Melinda Smith, M. A. contributed to this article. Last reviewed: December 2009. Cancer-Fighting Foods Your Best Defense for Staying Healthy By Kristi Patrice Carter †¢ [pic][pic] †¢ [pic] †¢ [pic] †¢ [pic] †¢ [pic] †¢ [pic] †¢ [pic] †¢ [pic] Pages:  Ã‚  1  Ã‚  2  Ã‚  3 Ever since you were a small child, you were told to eat a balanced diet consisting of fruits, grains, vegetables, meats and dairy products. You probably saw the USDA's Food Guide Pyramid plastered on the wall of your doctor's office and were familiar with its recommendations to eat 6 to 11 servings of bread, cereal, rice and pasta; 3 to 5 servings of vegetables; 2 to 4 servings of fruit; 2 to 3 servings of meat, poultry, fish, beans, eggs and nuts; and 2 to 3 servings of dairy products on a daily basis. But can you honestly say that you follow these guidelines? Do you eat a balanced diet low in fat, saturated fat and cholesterol? Do you eat enough fruits, vegetables and fiber? If you don't, you could be putting yourself at risk for developing certain types of cancer. Protecting Yourself According to the American Cancer Society, â€Å"As many as 500,000 Americans die from cancer each year. After cardiovascular disease, it is the second leading cause of death in the United States. † Although the specific causes of most cancers are not known, the U. S. government's National Cancer Institute estimates that â€Å"35 percent of cancer deaths are related to poor eating habits. † That's right, by simply modifying one's diet, 35 percent of these deaths may have been prevented. What can you do to protect yourself from this deadly disease? According to Barbara Rhodes, a licensed registered nurse in Illinois, â€Å"Although no single food can prevent cancer, you can reduce your risk of developing this disease by eating a low-fat, balanced diet, avoiding excess fat and increasing your intake of fruits, vegetables and fiber. By doing this, you strengthen your immune system and your body ultimately becomes a cancer-fighting powerhouse. † The Lowdown on Low-fat Why is it important to eat a low-fat diet and avoid excess fat? â€Å"Although fat is an essential nutrient which provides our bodies with energy and cushions our vital organs, too much fat is not good,† Rhodes says. â€Å"If we have a diet laden with too much fat, abnormal cell divisions may occur, which could increase our risk of colon, breast and prostate cancer. Therefore, meat-based diets are potentially very dangerous and must be limited. † â€Å"A healthy diet is one low in fat,† says Michelle Williams, a food preparation and dietary consultant for Cook County Hospital. You can easily lower your fat intake by eating less red meat (beef, pork or lamb); buying skim milk, low-fat dairy products such as yogurt and sour cream; purchasing lean cuts of meat and trimming excess fat before cooking; supplementing rich sauces with natural seasonings, spices and herbs; using egg whites instead of whole eggs; skimming excess fat off chilled soups and stews before eating; using low-fat margarine, salad dressing and mayonnaise; and using vegetable oil in place of melted butter. † Cancer-preventing Foods Another important element in a healthy diet is eating more fruits, vegetables and fiber. â€Å"Fruits and vegetables are high in fiber, low in fat and contain protective vitamins and minerals. They are a rich source with natural antioxidants, such as vitamins C and E and beta carotene, and may help block cell damage caused by free radicals. They also contain vitamin B (folic acid) which may inhibit the transformation of normal cells into malignant cells and strengthens your immune system. Fruits and vegetables also contain phytochemicals (naturally occurring plant chemicals) which appear to prevent some cancers and inhibit spread of malignant cells,† Rhodes says. â€Å"And fiber is important because it increases the movement of digested food through your intestines and ultimately reduces the amount of time your colon is exposed to cancer-promoting substances formed during digestion. † Which cancer-preventing foods should always be included in your grocery list? †¢ Fruits like apples, peaches, pears, apricots, berries, oranges and apricots †¢ Vegetables from the cabbage family †¢ Deep yellow and dark green vegetables like squash, turnips and their greens, Brussels sprouts and broccoli High-fiber foods like legumes (peas, beans and lentils) and whole-grain breads, rolls, pastas and cereals †¢ Reduced-calorie or low-fat salad dressings and margarines †¢ Low-fat dairy products like skim milk, skim-milk-based cheese and yogurt †¢ Lean cuts of beef, lamb and pork †¢ Fresh fish, shellfish, chicken or turkey †¢ Limited amounts of artificial products, synthetic chemicals and saturated fats By eating a low-fat balanced diet with plenty of fruits and vegetables, avoiding excess fat and getting enough fiber, you can reduce your chances of getting cancer. Not only will you become healthier, but your immune system will be enhanced and you will become a â€Å"cancer-fighting powerhouse. â€Å"

Premium Development Case

New England Health Maintenance Organization (HMO) is a regional not for profit managed care company that has its headquarters in Boston, MA, with over 500,000 enrollees within 25 different plans including Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont. A consortium of employers has shown interest in bidding on a managed care contract to be offered to the consortium’s 75,000 employees whom are locate in and around Nashua, New Hampshire. The consortium of employers includes companies such as IBM, Ford, and Prudential Insurance.The approach that New England has to the premium development is that the premiums received from the employers must cover the cost of the providing required healthcare services, also known as medical costs, and the costs of administering the plan and of establishing reserves, also known as other costs. Reserves are necessary to ensure that funds are available to pay providers when medical costs exceed the amount collected in pre mium payments (3901-3-13 Health Insurance Reserves, 2010). Due to New England HMO being a not for profit corporation, there is not explicitly include any type of profit element within the premium.A requirement to the reserve is set sufficiently high in order to ensure there are enough investments available to fund product growth and expansion. Therefore, part of the reserve requirements does constitute a profit. (Premium Development Case Study, 2007) A base per member per month (PMPM) is used in setting premiums by estimating the PMPM for each aspect of the plan’s coverage benefits. Setting the premiums also utilizes historical utilization as well as cost data. The co-payments are used a source of revenue to decrease medical cost and lessen the premiums.New England HMO adds fifteen percent to the total medical PMPM to cover any administrative costs that may incur and an additional five percent added for the reserve. The Individual Rate Factor is set at 1. 216 and the Family R ate Factor is set at 3. 356. The application of the given information allows the calculations to develop based on the levels of three co-payments, low, moderate, and high. The historical utilization and historical data for facility services is the same, regardless of the level of patient’s level of co-payment.The average fees are as follows: Inpatient Acute Care Services – Average daily free-for-service charge$1,200. 00 Surgical Procedures per case$1,300. 00 Skilled Nursing$430. 00 Mental Care – Average Daily Cost $540. 00 Emergency Room Care per visit$190. 00 The following services were calculated by dividing the cases, days, and/or the visits per year by 1,000. ServiceCalculationResult Inpatient Acute Care400/1,0000. 4 Skilled Nursing Facility Care25. 2/1,0000. 0252 Inpatient Mental Care64. 4/1,0000. 0644 Hospital Based-Surgery41. 7/1,0000. 0417 Emergency Room Care132/1,0000. 132Next, in order to attempt to find the base PMPM cost, the utilization data is mult iplied historical cost. Once this is completed, the product is then divided by twelve. For instance, the inpatient acute care cost is calculation by multiplying $1,200. 00 by 0. 4, then dividing by twelve. The cost would equal $40. This process will be used to calculate the remaining inpatient services. Using the information provided by the consortium, substance abuse as a base PMPM cost of $0. 41, while the base PMPM for outpatient services is $3. 43. The facility services total cost is $54. 25.Upon calculating the base PMPM costs, the patient co-payment adjustment factors must be determined. The high patient co-payment for acute services in Table 2 shows that the co-pay cost adjustment factor is 0. 9642 and 0. 9200 for the co-pay utilization adjustment factor (additional inpatient services information is located within the Premium Development Case Study). Once all factors have been defined, the adjusted PMPM cost can be calculated by multiplying the cost by the historical data and the historical utilization by utilization, then multiplying the two products and dividing by twelve.For example, for Inpatient Acute Care adjusted PMPM calculation is as follows: (1,200*1) * (0. 4*1)/12, which 40. The remaining inpatient services are calculated in the same manner, however the substance abuse adjusted PMPM cost and outpatient procedures adjusted PMPM cost is its base PMPM cost. In the end, once all adjusted PMPM costs have been calculated, the total is equal to $44. 74. Much of the information for the physician services is provided within the case study. In order to calculated the adjusted PMPM cost, the calculation is as follows: (3,400*utilization) * (175,000*cost)/1,000)/12For example, (3,400*1. 8900/4000) * (175,000*1. 6834)/1,000)/12 = 39. 44. The adjusted PMPM for physician services equals to $27. 24. The inflation rate is five percent; this plays a significant role within the analysis as like any other business, costs rise over time. In order to calculate the inflation adjusted PMPM cost for inpatient services, the adjusted PMPM cost is multiplied by the sum of 1 and the inflation rate of five percent, or 0. 05. ; this equal to $50. 79. The same calculations are done in order to solve the adjusted PMPM costs for the physician services. The total of this is $114. 9. The total medical PMPM amount is the sum of the physician services inflation adjusted PMPM cost ($114. 39) and then inpatient services adjusted PMPM costs ($50. 79), which equals to $165. 18. All other expenses are calculated by multiplying the total medical PMPM amount by the administrative expense percent. Therefore, $165. 18 * 0. 15 equals $24. 78. In order to calculate the reserve, the total medical PMPM amount is then multiplied by the reserve percentage. Therefore, $165. 18 * 0. 05 equals $8. 26. These amounts combined will equal the total other expenses, which calculated to equal ($8. 6 + $24. 78) $33. 04. The inflation adjusted PMPM is calculated in the same manner as other services. This amount will equal $34. 69. The total PMPM amount is equal to $199. 86. In order to calculate the final figure, the monthly premium rates, the total PMPM amount is multiplied by the premium factor rate, which is 1. 216 for single and 3. 356 for family. The single monthly premium rates will equal $199. 86 * 1. 216, which equals $243. 03. The family monthly premium rates will equal $199. 86 * 3. 356, which equals $670. 73.

The eNotes Blog Recognizing Frederick Douglass

Recognizing Frederick Douglass I was eager to see the books that won this year’s Pulitzer prizes and am thrilled with the results. (I mean, a book with trees as characters won the prize for fiction!) But I’m most pleased to see that David Blight’s biography Frederick Douglass: Prophet of Freedom won the Pulitzer for history, because any opportunity to raise the profile of Douglass’s life and legacy is welcome. A strong advocate for change, a compelling rhetorician, and a champion for civil rights, Frederick Douglass is a figure worth studying time and time again. That Blight’s biography won a Pulitzer is a testament to how Douglass’s works are â€Å"being recognized more and more† for the relevance they have to today’s world. Here at , we periodically revisit the works of one of the greatest orators and writers in American history and try our best to encourage others to read more about Frederick Douglass as well. (We even did a giveaway not long ago, so keep an eye out for the next one!) So, if you’re curious about learning more about Frederick Douglass or interested in teaching his works in your classroom, then have a look at the resources we have available for studying this American legend: An annotated text of Douglass’s essay â€Å"Reconstruction.† This essay contains Douglass’s claims for what has gone wrong during American Reconstruction, how â€Å"the occasion demands statesmanship,† and his proposal for action. I’ve written about this piece before and always find that Douglass’s incisive comments apply to politics to this day. In addition to the annotated text, we provide a study guide with summary and analysis sections. An annotated text of Douglass’s speech â€Å"What to the Slave Is the Fourth of July?† This fiery, impassioned speech is one of the most poignant examples of the power of rhetoric, showcasing Douglass’s skills as a compelling orator. In addition to the annotated text, we provide a study guide containing a summary and analysis of the speech’s historical context, literary devices, and rhetorical devices. A biography of Frederick Douglass, supplemented with analyses and critical essays. While Blight’s biography has been hailed as â€Å"the definitive biography of Frederick Douglass† (which we’re obviously willing to concede), our biography page contains useful facts, trivia, and critical essays on the man’s life and legacy. A study guide for Narrative of the Life of Frederick Douglass, an American Slave. Arguably Frederick Douglass’s most-famous work, Narrative of the Life of Frederick Douglass is a powerful, honest account of his experiences as a slave and his path to freedom. This study guide is complete with a summary, themes, characters, analysis, critical essays, and a reference section, as well as a chapter-by-chapter lesson plan that includes a multiple-choice test, essay portion, and answer key.

Rules for Latin Syllabification

Rules for Latin Syllabification The syllables in the first line of Vergils Aeneid separated word-internally by /:(1) r/ma vi/rà ºm/que c/no Trà ³/jae qui prà ­/mus ab à ³/ris Knowing the way Latin words are divided into syllables will help you to pronounce Latin and translate Latin poetry. There are a few basic points you need to know. As with most things, there are always exceptions. The number of syllables the number of vowels/diphthongs pronounced separately. For example, Caesar contains 1 vowel and one diphthong, so there are 2 syllables: Cae-sar. There are no silent vowels in Latin. Exercise:Q.How many syllables in the English word alphabet?A.There are 3 in alphabet and they center around the 3 vowels in the word.Q.How many syllables in the English word same?A.There are 2 vowels in same, but 1 is silent, so there is only one syllable.Q.How many syllables in the Latin example (1) above?A.15Check for vowels. The first word r/ma has two vowels and two syllables, the second word vi/rà ºm/que has three vowels and three syllables. Whats that you say? There are 4 vowels? The u after q acts as it does in English, and doesnt count. The third word c/no has two vowels and two syllables. The fourth word Trà ³/jae has three vowels, but only two are pronounced separately, since the ae, being a diphthong (see below), is pronounced together. You can analyze the last three words (qui prà ­/mus ab à ³/ris) on your own. The Latin diphthongs are ae (earlier, ai), au, ei, eu, oe, and ui (rare) [See Wheelock].Examples:TrojaeAurum golddeinde thenEuropaproelium battlecui whoLike English, the Latin syllable divides between consonants or after a vowel and before a consonant. For example, mitto has two vowels and therefore two syllables. Mitto has a double consonant, so the syllable is divided between the ts: mit-to.More examples:Caesar: Cae-sarDeinde: dein-deProelium: proe-li-umThis page is a quick tip about syllables, not stress, but since they are related, and both are necessary for a reasonable pronunciation of Latin, you may be interested. Stress is normally on the penultimate (second to last) syllable if it is long and on the one before (the antepenultimate), otherwise, generally. If you look up amicus in a Latin dictionary, there will be a long mark or macron on the i. That means the i is long and so the syllable is stressed. If there is a diphthong in the penultimate syllable or it is followed by tw o consonants, it is generally counted as long and therefore stressed.Look at the opening example:(1) r/ma vi/rà ºm/que c/no Trà ³/jae qui prà ­/mus ab à ³/risThe ictus is marked with an accent mark. This shows the stress.

Discuss three ways that technological innovation has worked to the Essay

Discuss three ways that technological innovation has worked to the detriment of organizational dynamics or to the detriment of s - Essay Example Take the case of patent applications. Technological innovation has been linked to the increase in patent applications. This is due to the extension of patent domain to new objects such as research tools, software, business methods, artificially engineered organisms and genes. Moreover new players like public agencies and universities have also entered the patent domain thereby making the market more competitive. In the past twenty years, we have witnessed a rapid growth in the rates of patents which also includes patenting the scientific resources and results. It has been observed that the patent applications from US corporations conducted from 1988 – 2000 have more than doubled. In other words, patents have acquired strategic value. A classic example in this context is that of Texas Instruments. This company is estimated to have profited around one billion dollars from patent licenses and settlements due to its aggressive enforcement policy. The above mentioned aspects have l ed to an increase in the patenting rates. This has subsequently increased the litigation expenses. According to the US Department of Commerce, patent litigation that commenced in the year 1991, led to an overall legal expenditure by US firms which were at least 25% of the cost of basic research conducted by these firms in 1991 (Dosi, Marengo & Pasquali, 2006). An important breakthrough in technology is the invention of computers and other advanced tools which provides accurate and fast results. Advanced and innovative software has provided us a platform to interact online with each other. The advent of e-mail, intranet, social networking tools like Facebook, Twitter etc. has made it possible for people to interact online. Previously, people used to meet each other and visit their close friends and relatives. Occasions such as birthdays, anniversaries were celebrated and people visited each other in person. However, with the advent of online tools people no longer care to visit their close friends and relatives. Instead they interact with them online with the various internet tools that have been invented. Nowadays, these tools are a means to keep in touch with each other and hence face-to-face interaction has lessened to quite an extent. Another negative effect of computers is that it has led to reduction in manual labor. Previously, all types of work needed to be done manually and this meant higher demand for laborers. With automation, the entire scenario has changed. Many people may argue that the job market has become more competitive with all firms struggling to put in their best to remain in market. However, the newspaper industry has been hit very hard as technological innovation has paved the way for advertising and market promotion actions through the web. Nowadays firms and organizations prefer to promote their products and services through the internet, online magazines and brochures which have a wider public appeal. This is one of the main reasons w hy most newspaper firms have ceased to remain in the market and in most countries it has been observed that only a handful of such companies remain in market. Technological innovation is a vicious cycle. Take the example of the automobile industry. With the advances made in technology, new automobiles are being designed taking into account the consumer comfort and luxury. In most countries people consider car to be a necessity as they prefer to commute driving their own automobile. This has led to an increase in the pollution levels