The United States Of America free essay sample

The USA is probably the biggest state known to mankind. It is arranged in the cardinal bit of the North American landmass. The nation of the USA is more than 9,000,000 square kilometers. It is washed by the Pacific Ocean and by the Atlantic Ocean. The most northern bit of the USA is Alaska, the biggest region, isolated from the rest of the state by Canada. The number of inhabitants in the United States is around 250 million individuals, a large portion of the individuals live in towns. People groups of various nationalities live in the USA, The authority semantic correspondence of the state is English. The capital of the state is Washington. It was named to pay tribute to the principal President, George Washington. As the USA is a major express, the clime is diverse in various parts. For outline, the Pacific beach is a piece of mellow winters and warm, dry summers, however the eastern Continental part is watered with precipitation. We will compose a custom exposition test on The United States Of America or then again any comparative subject explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page The part around the Great Lakes has impermanent conditions. There are numerous mountains in the USA. For representation, the most elevated extremums of the Cordillera in the USA are 6,193 and 4,418 meters. The central waterway of the state is the - Mississippi. In any case, there are numerous other incredible waterways in the USA: the Colorado in the South and the Columbia in the north West. There are five Great Lakes between the USA and Canada. The USA creates more than 52 for each penny of the universe s maize, wheat, cotton baccy. There are numerous enormous metropoliss in the state. They are Washington ( the capital of the state ) , New York ( the city of differentiations, financial and concern Center of the USA ) , Boston ( there are numerous schools and colleges in it ) , Chicago ( one of the greatest modern metropoliss in the USA ) , San Francisco, Los Angeles, Philadelphia, Detroit ( perhaps the greatest focal point of the vehicle business ) . The USA has an Academy of Sciences. There are numerous logical foundations, exhibition halls, libraries, theaters and other fascinating topographic focuses with regards to the state. The USA is an amazingly evolved modern state. The USA is plentiful in mineral assets, for example, aluminum, salt, Zn, Cus, and others. The state is wealthy in coal, petroleum gas, gold and Ag, too much. It holds one of the primary topographic focuses known to man for the creation of coal, Fe, oil, flammable gas. Such ventures as machine-building, transport building are very evolved in the state. American agribusiness delivers a cluster of supplement stocks: grain, natural product, veggies. The USA is a government popular government, abiding of 50 territories. Every one of these territories has its ain specialists. Congress is the American Parliament which comprises of two Chambers. The president is the caput of the area and the specialists. He is chosen for four mature ages.

Rhetoric in American Politics

Presentation Some people accept that free discourse is a definitive portrayal of freedom. They contend that more discourse is better than no discourse at all independent of its way of articulation. In any case, these examiners overlook that political talk in the US has results and that occasionally it can go overboard.Advertising We will compose a custom exposition test on Rhetoric in American Politics explicitly for you for just $16.05 $11/page Learn More The hazardous atmosphere The American political atmosphere is described by the defamation of politicians’ adversaries. In spite of the fact that this is the same old thing in governmental issues, one must take alert when the propensity gets incorrect and adolescent (Hunt 13). Words, in today’s political scene, are not used to accomplish exact points however to destroy everything that can be harmed. Accordingly, more clear musings and completely created thoughts get suffocated in national discussions. American politica l talk has arrived at overdrive levels and in this manner, made it a lot simpler for legislators to rehearse divided governmental issues, or make statements that they may not so much mean. They promise audience members that their adversaries are a lot of more terrible and this misshapes reality. An a valid example was the contortion of Barrack Obama’s foundation. Political talk prompted falsehood about his religion and his citizenship. A few people implied that he was a Muslim and was not devoted to the country. Such misleading statements breed a climate of allegation and withdrawal, which check the very rules that make this country so solid. Various Americans are exceptionally bothered by furious legislative issues in the land. Around 70% of Americans accept that the negative political climate in the nation is adverse to vote based system. Numerous people’s political desires are lessening inferable from this situation and the nation seems, by all accounts, to be going off course (Lawler and Schaefer 94). Various perceptions have likewise demonstrated that it isn't only the political and social prosperity of society that will be influenced by over the top political talk yet the physical prosperity too. Political talk can arrive at levels that show as vicious conduct. One such case was the shooting of Gabrielle Gifford, a delegate of Arizona. The last chief was shot and harmed antagonistically during an intelligent meeting with her electorate at a supermarket. The aggressor terminated at twenty individuals, including Gifford, after the agent had tweeted that she was at that area. While examinations are yet to build up whether the shootings were roused by the assailant’s mental state or more profound policy driven issues, it is as yet basic to recall the last choice is very plausible. The sharp, hostile language focused on government has improved the probability of brutal incidents.Advertising Looking for exposition on talk? We should check whether we can support you! Get your first paper with 15% OFF Learn More Most lawmakers utilize radio syndicated programs, web online journals, long range informal communication sites like Twitter, network shows and a lot more to scatter horrendous talk. On account of Gabrielle Gifford, the province of Arizona had gotten profoundly energized before her assault (Kaplan 22). Numerous occupants in this state questioned government and were suspicious about their medicinal services laws. This every day presentation to ruinous talk through different news sources may have violently affected the individuals of the state. It was particularly likely among flimsy people than even ones. Expanding boisterous ambushes in certain political discussions has increased security concerns. Numerous fights have turned savage during open gatherings. One such case was the human services banter that occurred in 2010. Indeed, even passing dangers against congressmen were normal. End The utilization of politi cal talk for egotistical additions among government officials has reared an air of disruptive and rough legislative issues. This has been showed through separation and vicious encounters against political pioneers. Works Cited Hunt, Geoffrey. We need increasingly political talk, not less. 12 Jan. 2011. Web. https://www.americanthinker.com/articles/2011/01/we_need_more_political_rhetori.html Kaplan, Marty. 2011 January 8. â€Å"The lock and burden talk of American legislative issues isn’t only a metaphor.† The Huffington Post 8 Jan. 2011: 22. Print. Lawler, Peter and Robert Schaefer. American political talk. NY: Rowman and Littlefield distributers, 2000. Print. This exposition on Rhetoric in American Politics was composed and presented by client Hyperion to help you with your own examinations. You are allowed to utilize it for research and reference purposes so as to compose your own paper; in any case, you should refer to it in like manner. You can give your paper here.

Prophet Essays - Christian Eschatology, Purgatory, Prophecy

Prophet Essays - Christian Eschatology, Purgatory, Prophecy Prophet The Prophet Period 4 Patrick Coleman In the prophet it doesn't disclose to you how to live, yet it reveals to you how life works. I don't concur with everything that is stated, however all in all I like the message the book sends. I have taken my five most loved parts, and separated them for this report. Eating and Drinking-I think he is stating that we don't need to become veggie lovers, however we should never take more than we need. I think this applies well to average executing of meat, however when he says we ought to be troubled and apologize to an apple that we chomp is the place I don't concur. Giving-This is one of only a handful scarcely any parts I completely concurred with. My preferred statement originated from this section, You give yet little when you give of your assets. It is the point at which you give of yourself that you really give. And afterward they talk about how the normal man doesn't have a clue how the needy individual feels until they have been poor themselves. Wrongdoing and Punishment-He takes an intriguing position on discipline by recommending a kind of limbo. He says that, And for that wrong dedicated must you thump and hold up some time unnoticed at the door of the favored. He additionally says the type of a discipline is living with the wrongdoing you did. That you will feel distress for what you have done. Demise He says that passing is equivalent to life. They are one, similar to the stream and ocean are one. This is the last section, since I think it is the hardest for us to comprehend. Furthermore, I don't believe that we can ever get passing, as we are living. However, we ought not fear it.

American life Essay

Who says grabbers are just for stories? The absolute best descriptive pieces begin with sentences that catch the readers’ consideration. The creators from various artistic classes give their own consideration grabbers to make their pieces increasingly appealing and more tension from the earliest starting point up to the end. As per Ruhanie Perera (2007), â€Å"Each maker carries with them their qualities and convictions formed by their training and introduction to English Literature, yet their pursuit is the equivalent †for the innovative, the striking, the sharp and the new. † However, descriptive grabbers are not made distinctly for stories yet for a wide range of circumstances like in the field of soccer. Where it counts in the sea hides a risky executing machine. This is one of the models that we hear in soccer. It is a type of consideration grabber to cause the players to get mindful of their activities. From this viewpoint, it just implies that any consideration grabber must be new from the ears, brains, and eyes of the crowd. Huge numbers of us like soccer. We watch various plays and games on TV about soccer. This is by one way or another piece of American life. Along these lines, we hear diverse consideration grabbers from the broadcasters, mentors, and players. At the point when these individuals state their interpretive grabber, the group hollers and feels that there is promise for progress. Like accounts, considerations grabbers could be heard in the start of the occasion. Descriptive grabbers make every circumstance honorable and incredible. In soccer, consideration grabber implies a ton of things †it turns into the life and continuance of the group to try sincerely and dominate the match. That is the reason even in this field, informative grabber is significant. In end to this, it tends to be said that explanatory grabbers lift the brains and hearts of the crowd or perusers. It gives power and roundabout control to the onlookers. The individuals may not understand this yet they were impacted in opportunity and captivation. Book reference Ruhanie Perera. â€Å"They were the consideration grabbers. † Sunday Times. Sunday, April 01, 2007, Vol. 41-No. 44. 31 October 2008. http://sundaytimes. lk/070401/Plus/020_pls. html

The Story Of @MITStudents

The Story Of @MITStudents Our office is not on Twitter (although our bot is), but 89 other offices at MIT are. Among them is @MITStudents, an account maintained by Kellen Manning, Communications Coordinator for MITs Division of Student Life  (he also oversees their Instagram and tumblr). Kellen and I are usually at the gym at the same time, and the other day we were talking about @MITStudents, which I myself follow and often interact with. He offered to send me an explanation of what DSL is trying to do with it (and, for that matter, what DSL is), which I wanted to post here. What do you know about the Division of Student Life (DSL) at MIT? Essentially DSL promotes the idea that learning doesn’t just happen in the classroom. Learning happens through making connections, exploring opportunities, and discovering who you are. That’s all well and good, but you are probably still wondering, “What is DSL?” Well, we are comprised of numerous departments and special programs meant to support and enhance students’ lives outside of the classroom. These include the Department of Athletics, Physical Education, and Recreation (DAPER), Religious Life, Residential Life and Dining, Student Activities, Campus Activities Complex, the Hobby Shop, the Public Service Center, Student Development, and Student Outreach and Support. Through their activities, DSL offers students and the MIT community many opportunities to learn about and experience a multitude of things. To complement their work, we want to start highlighting the experiences that you create. So we rethought our social media efforts and decided to focus more on you! Through our social media accounts we want to hear about and highlight events that you are excited about. We want to know about your projects. We want to help our growing base of followers experience MIT through your eyes. To put it simply, we want MIT students to help us communicate what life is like for MIT students: the good, the bad, and the meh. We also plan on following your experience a lot like we did during commencement last year when we followed Andrea Nickerson ’14 through her last month as an MIT student. We also are following a crop of incoming freshmen this summer. Whether students were part of dance performances, enjoying a concert, or just slack lining in North Court, if we see it we pushed it out. So feel free to tweet at us, email us pictures and captions, link us to videos and tag us in Instagram photos. If you have questions that you want to ask the community, send them to us or tweet at us and we’ll push them back out to the best of our ability. If your student group is hosting an event or performance, or you’re recruiting new members, please let us know. Basically we want to highlight your journeys, interests, and causes. We hope to hear from you!

Technological Unemployment Due to Automation - Free Essay Example

Automation, historically speaking, has been the processes or procedures performed, in businesses like manufacturing, without aid from people. Automation or automatic control is the use of various control systems for operating equipment such as machinery, processes in factories, boilers, and heat treating ovens, switching on telephone networks, steering and stabilization of ships, aircraft and other applications and vehicles with minimal or reduced human intervention (Rifkin 66). As I have learned through my research, automation has impacted the business environment as early as Eli Whitney and the Cotton Gin. Concerns over automation and joblessness during the 1950s and early 1960s were strong enough that in 1964, President Lyndon B. Johnson empaneled a Blue-Ribbon National Commission on Technology, Automation, and Economic Progress to confront the productivity problem of that period†specifically, the problem that productivity was rising so fast it might outstrip demand for labor (Autor 3). It is believed that one day there will be fewer jobs for humans because of automation. President Johnsonrs commission took the reality of technological disruption as severe enough that it recommended, as one newspaper (The Herald-Post 1966) reported, a guaranteed minimum income for each family and two years of free education in either community or vocational colleges (3). Automation brings an understandable level of anxiety to the workers possibly displaced and to policymakers trying to lead the nation while maintaining a healthy and robust economy. In this paper, I seek to understand and explain why African-Americans should be concerned with the possibilities of technological unemployment due to automation. Automation is used today in several fields including manufacturing, home, and office. Some major companies in production, like Toyota, use automation to build vehicles. In the home Alphabet, the parent company of Google produces a home thermostat called Nest that allows homeowners to automate their heating and cooling needs. Lastly, Avaya Communications produces network communication systems for the office. All of these companies have experienced increases in productivity as a result of automation. According to the Bureau of Labor and Statistics (BLS), in 2016 African-Americans made up 12.3 percent or 19.6 million of the 159.2 total workforces (Rolen). African-Americans hold many different positions in our economy but an overrepresentation of employees in the public sector, federal, state, and local governments. According to the BLS, African-Americans comprise 20 percent of the workforce in the public sector and 7.1 percent of transportation and warehousing, and utilities (Rolen). Because of African-American over-representation in these industries, it is clear there is potential for African-Americans to be greatly impacted by automation in the public sector and the transportation industry. Trucking jobs have been an opportunity for black, Hispanic, and Native American workers, who have faced serious, race-based barriers to entry in other blue collar jobs and are now overrepresented in the industry (Marshall). Take the transportation industry, for example, Tesla Motor is set to begin production on an electric Semi capable of driving 500 miles on a charge while hauling 80,000 pounds of freight (Marshall). Additionally, the Semi truck is expected to be semi-autonomous, capable of driving itself on highways. When a fully automated semi-truck is thoroughly dispersed into the market, all driving industries could lose up to 300,000 jobs a year (Marshall). In addition to the trucking industry, Frey and Osborne (2013) found that 47% of jobs in the US and 57% of jobs on average in the OECD countries are at risk of automation. Even education, one of the most labor-intensive sectors, will most likely be significantly impacted by improved user interfaces and algorithms building upon big data. The recent growth in MOOCs (Massive Open Online Courses) has begun to generate large datasets detailing how students interact on forums, their diligence in completing assignments and viewing lectures, and their ultimate grades (Simonite, 2013; Breslow, et al., 2013). To my knowledge, I could find no study that quantified the effects of what recent technological progress is likely to mean for the future of employment of African-Americans. I conclude we all should be concerned about the impact of automation on labor. Technologies that are disruptive to their markets are guaranteed to cause some anxiety as we can predict more clearly which industries will be impacted but cannot predict those industries automation may create.

TOCFL - Test of Chinese as a Foreign Language

TOCFL stands for Test of Chinese as a Foreign Language, obviously meant to be associated with TOEFL (Test of English as a Foreign Language) and is the standardized Mandarin proficiency exam in Taiwan. The Mainland Chinese counterpart is the HSK (Hà  nyÇ” ShuÇ pà ­ng KÇŽoshà ¬). TOCFL is arranged by the Ministry of Education and held regularly both in Taiwan and abroad. The exam was previously known as TOP (Test of Proficiency). Six Levels of Proficiency Just like the HSK, TOCFL consists of six levels, although the final level is still under development. What these levels mean exactly depends on whom youre asking, but lets look at a quick overview: TOCFL level TOCFL name CEFR HSK level* 1 A1 3 2 A2 4 3 B1 5 4 B2 6 5 C1 6 C2 *Comparing proficiency exams is notoriously difficult, but this assessment made by  Fachverbands Chinesisch, a German association for teaching and promoting the Chinese language. There is no official HSK to CEFR conversion table (there was, but it was retracted after being criticized as too optimistic). Even though there are six distinct levels, there are actually only three tests (bands): A, B,  and C. That means that you can achieve levels 1 and 2 on the same test (band A), depending on your final score, levels 3 and 4 on the same test (band B), and levels 5 and 6 on the same test (band C). The tests are structured so that they become gradually  more difficult, allowing for a wider span of difficulty for each test. In order to pass a certain level, you not only need to reach a certain total score, you also have to meet certain minimum requirements for each separate parts. Thus, you wont pass if your reading ability is lousy, even if your listening ability is stellar. Resources Official TOCFL website -  This is where you go for basic information about test locations and dates, as well as any other kind of official information. You can also sign up for exams here, both in Taiwan and abroad.TOCFL mock exams - There is one mock exam for listening and one for reading. In comparison with HSK, this isnt much, so if you want more, we suggest you check the resources for HSK and use the table in this article to figure out roughly what level you should aim for.

Raising A Child As A Single Parent - 855 Words

Raising children in today’s society can prove to be a very difficult task. Parenthood is challenging even with the best of circumstances. With one parent, the challenges are multiplied. Single Parenthood is very common in the United States. In fact in 2013, 28% of children in the US were living in single-parent homes. Having children in the US ages 0 thru 18 as a single parent can be very costly and come with many responsibilities. For most single parents the most difficult part of being a parent is the financial responsibilities. The average cost of raising a child born in 2013 up until age eighteen for a middle income family is approximately $245,340.00. Education is also an important responsibility when having children. Nurturing although it is something that should come naturally to a person, can prove to be difficult and is a very important responsibility. All of these responsibilities combined are only a fraction as to what goes into raising a child. Unfortunately single parents may have a far more difficult time raising a child due to the different economical, social, and personal task each individual may face. Financial Responsibility and planning can be challenging for anyone, including single parents. Some financial struggles a single parent may face are shelter, food, and clothing. Single parents face more hardships than a two parent household when it comes to providing shelter for their families. In 2013 alone, over 70% of families in homeless shelters were fromShow MoreRelatedShould parents assume equal responsibilities when raising a child?1330 Words   |  6 Pageschildren† ( 2). Parents have an obligation to take care for children, so that when they grow up they are able to become a person who is strong enough to support himself. But there are different opinions whether raising a child should be shared equally between parents. One group thinks that it is essential for a child to grow up with the love and care of both parents. Meanwhile, others believe that child raising should be shared in a way that suits the family. While single parents argue that evenRead MoreShould Paren ts Assume Equal Responsibility When Raising a Child?1582 Words   |  7 Pageschildren† (Rowe 2). Your parents’ have an obligation to take care for you, so that when you grow up you are able to become a person who is strong enough to support yourself. But there are different opinions whether child raisin should be shared equally between parents. A group of people think that is essential for a child to grow up with the love and care of both parents. Some people’s opinion is that child rising should be shared in a way that suits the family. While single parents argue that even withoutRead MoreChildren Growing Up Into Single Family Homes1541 Words   |  7 Pagesyears, children growing up in single family homes has been discovered as problems. â€Å"At first glance, defending single mothers and their children. Raised by a strong and resourceful single mother, I turned out OK† (Wilcox). Being raised up with one parent seems to be stressful and impossible, bu t for decades its become possible to happen. In the society today, there are children growing up overcoming emotional stages and achieving their goals whether if they have both parents to show them difficult pathsRead MoreSingle Parent vs. Two Parent1229 Words   |  5 PagesSingle Parent Home vs. Two Parent Home Kendria Threatt COM 170/ Elements of University Composition and Communication I December 7, 2011 Monique Derr Single Parent Home vs. Two Parent Home How do you feel about raising children in a single parent home or in a home where both parents are present? It is very shocking to know that most people do not think about these situations before starting a family. In today’sRead MoreFamily Structure Of A Single Parent938 Words   |  4 PagesFamily structure has significantly changed from the 1940’s. The norm was that 70% of children lived with both biological parents. In the 1990’s it dropped to 60.2 % (Gennetian, 2005). In 2010, the U.S. Census Bureau’s 2008 American Community Survey provided that only 45% of children were raised within an intact family (U.S. Bureau of the Census, 2008). Society and culture is changing, and what wasn’t â€Å"acceptable† by many cultures such as divorce, blended families, interracial marriage, and same-sexRead MoreShould both Parents Take Equal Responsibility in Raising a Children728 Words   |  3 Pagesand both parents should take care of these seed as they grow. In fact, there is argument in these important issue that is both parents should assume equal responsibility for raising children. However, some people believe that the mother is the first one to teach children many epacts for their life and some defend that father is prime factor in the children life. Indeed, I assume that both parents are prime factors in the children life, also there are many studies prove that both parents can giveRead MoreShould Single Parents be allowed to Adopt?845 Words   |  3 Pagesnumber of single-parent adoptions. Why would a successful, independent single man or woman want to give up his or her freedom and assume the responsibilities of raising a child? The trend is mainly due to the fact that the desire to nurture and share life as a family has become to be a strong need that is felt by a large number of people, and one that is not exclusively to married people or couples. The purpose of adoption is to provide children a loving and caring parent. Sing le parents should beRead MoreShould A Child Be Raised Together Or Alone?1256 Words   |  6 Pages Should a Child Be Raised Together or Alone? Britny Valdez â€Æ' Should a Child Be Raised Together or Alone? â€Å"Single-parent families now constitute 30 percent of all families with minor children and are the most rapidly growing families in America† (as cited in Dowd, 1997). When people hear the term ‘single-parent’ they automatically think it means a person who is the legal guardian of a child or children. It is typical for a single-parent to be a woman, because the statistics on the proportionRead MoreBeing A Single Parent Or Not?1456 Words   |  6 Pagesconsisting of two parents rearing their children, a spouse and children. This definition is now challenged, as the years have gone on the way we think and picture a family has changed. It is no longer a married stay at home mom and bread earning dad with their little son and daughter. Now a family can be a single mom, a single dad, a same sex couple or a separated or divorced mother and father with their biological or adopted child or children. Over the years the percentage of single fathers has onlyRead MoreEss ay on One Parent Family vs Two Parent Family901 Words   |  4 Pageshome by either both parents, mother and father or by a single parent. I feel that if it is a loving home where each parent is taking part in raising the child it is beneficial to the child. On the other hand if both parents argue all the time than it is not beneficial for the child’s upbringing. In having just one custodial parent the child is better off because the one parent will be able to provide a better stable social environment. Few parents decide on becoming single parents other reasons why

The Upside to Academic Interests Essay Samples

The Upside to Academic Interests Essay Samples Academic Interests Essay Samples and Academic Interests Essay Samples - The Perfect Combination EssayEdge is the major application essay editing service on the planet. You may use the samples as a foundation for working out how to write in the right style. In other words, an academic essay may be an evidence of the depth of your research procedures and the rest of the activities you've executed so you can support the content of your written output. Finding the balance to communicate this information appropriately may be hard. These instructions will provide you with some helpful hints about how to compose an honors application essay. They've also been handling different application essay topics over the last few years and so have the adequate experience needed to compose impressive papers. This is sometimes a terrific tactic, but you have to be sure to use essay samples the right way. Try to remember, an admission essay sample may be a good way to find out more about the writing procedure and understand the task better. The author starts with a rather comprehensive story of an event or description of an individual or place. If he is a person, then their first name is used first. Academic Interests Essay Samples Explained If you don't, you're able to actually hurt your odds of admission. Demonstrating your understanding of the opportunities which make Penn unique is essential to completing UPenn's supplemental essay. The readers, however, may want to hear more than just 1 career objective. For instance, a recruiter doesn't have to request the private information of a contract employee or a consultant whose service is obligatory for only a brief period. Academic Interests Essay Samples: the Ultimate Convenience! One of the most difficult features of college life is finances. A good example is when someone joins a badminton club, which is a little group of sports enthusiasts who wish to keep a healthful lifestyle through a standard sport. Once an individual is affiliated to a specific sport, they begin to get engaged in a sound physical activity. He usually joins a club in order to ensure that they have a regular way of maintaining a healthy lifestyle. This paragraph is also a possiblity to portray your capability to raise and conquer challenges in your specified field. In conclusion, it appears that assignment essays continue to get a prominent part in tertiary education as an assessment tool. By weaving narration throughout the paragraph, you'll be in a position to portray a more authentic and distinctive story. This example demonstrates that even for an engineer with years of experience in the specialty, the basics of private essay writing remain the exact same. Type of Academic Interests Essay Samples Bridget's essay is quite strong, but there continue to be a couple little things that could be made better. A self-introduction essay, since the name suggest, is a component of essay containing the simple info about the writer. It's possible to access the writer who's writing your essay directly so that you could make any correction. It lets your readers know the subject of your academic essay and what they are able to anticipate from the full article. When you are requested to compose an essay, attempt to discover some samples (models) of similar writing and learn how to observe the craft of the writer. If you're to really gain from model essays, you want to understand how to read the techniques of the writer'. To say a single sentence about love is seemingly not possible. Well, not merely are there so many different kinds of love, defining love is notoriously complicated. Another form of love that's commonly inbuilt is universal love. While others are going to say unconditional love is the sole pure kind of love. Academic Interests Essay Samples - What Is It? One of the things which students commonly forget in academic writing is the usage of the third individual. 1 approach to make the most o f the small space you have is to seek out a means to relate your very first and second choice majors. That's the reason why I will do anything in my power to aid someone in need, even if he or she's a comprehensive stranger. Obviously, understanding how to clean burning oil isn't high on the list of things every 9-year-old should know. It is very important to capture the interest of the admission tutors irrespective of how strict they may appear to be. Thus, the essay is supposed to coincide with the applicant's qualities and interests in order for it to boost the possibility of admission. Composing an appropriate career goals essay can be hard should you not actually have any ambitions. Writing an essay that explains what goals that you want to pursue in your upcoming career is a skill you are going to have to demonstrate a lot for a student. You can and ought to mention the specific school to which you're applying. Bear in mind that all scholarship applications are different, which means you might need to design your essay to fulfill those particular requirements. Avoid mentioning on-the-job experiences that are not directly related with the field you're applying for. The colleges and courses involved attract a number of the brightest minds in the nation.

Harriet Tubm Conductor On The Underground Railroad

Her intentions were pure and for the people that were in need. She only wanted for everyone to be treated with equal respect and rights. Though she went through her entire life without being able to read or write, she still managed to lead a self-fulfilling life. This woman is Harriet Tubman. In the book, Harriet Tubman: Conductor on the Underground Railroad, Ann Petry goes through her major stages of her life. First, the book starts out sometime in 1821, on the Brodas Plantation in Dorchester County, Maryland where Harriet was born. Ben Ross and Harriet Greene (Old Rit), who were both well respected by the plantation owner and the other slaves, had just had another child. It was a girl. They named her Araminta, which would later†¦show more content†¦Nothing changed when she returned. She was stuck doing the same jobs, and was returned because Mrs. Cook believed that she was â€Å"hopelessly stupid†. She given back to the Brodas, but was hired out once more a s a child nurse. She hated this work just as much because she was stuck inside all day. She was brutally beaten and was whipped on multiple occasions because the baby didn’t sleep through the night. Eventually, she ran away. It was a failure. Minta spent most of this trip fighting off pigs to eat the slop that was fed to them After approximately five days she returned because she was tired and starving. †By and by when I was almost tuckered out, I came to a great big pigpen. There was an old sow there, and perhaps eight or ten little pigs. I was too little to climb into it, but I stumbled over the high part and fell in on the ground; I was so beaten out that I could not stir. And there I stay from Friday until the next Tuesday, fighting with those little pigs for potato peelings and other scraps that came sown in the trough.† Then, she was brutally punished, and returned because she was disloyal. Minta though felt that she had won a battle. She from then on worked in the fields. She was finally old enough to earn the name Harriet. She became a strong woman, and was being more and more involved with helping the plantation. More stories were being told about slavery and new talk was being presented about the Underground

How Does Iago Corrup Othello in Shakespear’s Othello Free Essays

Finally, the most effective way Iago poisons Othello’s mind is by changing the appearance of reality. He will cover it up with lies and Othello will be forced to believe him because he will be too submerged in doubt and suspicion to see the truth. In act 3, scene 3, when Cassion parts from Desdemona, Iago makes it appear as if Cassio â€Å"steal away so guilty-like†(Shakespeare, act 3, scene 3) because he did not want to be seen with Desdemona. We will write a custom essay sample on How Does Iago Corrup Othello in Shakespear’s Othello or any similar topic only for you Order Now While it appears really bad from Othello point of view, the reality of it is completely different. Cassio, who has been demoted, wishes to gain back his good will with Othello with Desdemona’s help. Iago tricks Othello by making him believe that every seemingly harmless encounter between Cassio and Desdemona are actually lies and that they are seeing each other behind his back. To the readers of the play it is quite obvious the nature of their encounter but to Othello who judges with eyes clouded by jealousy, he can only see the harm being done. Othello is unable to make a rational decision because he is too deep in madness. Iago has poisoned his mind and ruined his judgement. To further poison Othello’s mind, Iago will set up Cassio and Othello. In act 4, scene 1, while Othello is hidden in the shadows; Iago approaches Cassio and starts a conversation with him. Othello believes the base of the conversation will be about his wife Desdemona because it is what Iago told him he would do: interrogate Cassio about Desdemona. But the reality of it is different. Iago is actually talking to Cassio about Bianca. Othello is caught up in the illusion; he now truly believes that Desdemona is unfaithful towards him. Jealousy clouds one’s mind. Othello in able to see that Iago is playing him; he is too deep in his own illusions to notice that he is being used. Because Othello’s judgement is clouded, Iago is able to make things appear differently. With his rational thinking gone, Othello is incapable of differencing reality from lies. The more he is poison, the more he degrades. His speech deteriorates, he has epileptic attacks and burst into rage. His actions are proof of his mental state. He is turmoil because of what Iago has made him believe, because of what Iago has made him see. Not only does Iago make scenes appear differently, he himself is an example of appearance vs. reality. Trough out the eyes of the other characters in the play, Iago appears â€Å"full of love and honesty†; Othello even says that â€Å"Iago is most honest†. In Criminal Types in Shakespeare, August Goll cites: â€Å"Iago appears to every one as the clever head, the man who knows the world and sees things clearly, who describes things as he sees them without mincing matters-the free-spoken, honest friend bold and rough: for this reason they all seek him in their various difficulties, Desdemona, Cassio, Emilia, Roderigo. (Goll, 218) Iago makes himself appear intentioned to the feeling of others. When they are faced with difficulties he offers them advices. Othello looks to Iago for advice on how to deal with the situation he faces, he asks him to help him in his vengeance. Iago true personality is someone who is egocentric, full of malice. He only thinks about himself. He does not help the Moor with good intention; he believes that he cheated with his wife and thus wishes to get his revenge. He does not give advice to Cassio because he feels obliged to help a comrade; he does it to fulfill his plan. To conclude, Iago is one of Shakespeare most vile villain. He made Othello fall into despair; he made him believe that Desdemona was unfaithful to him when it was nothing but lies. He used many tricks to poison Othello’s mind, he became his friend with him and trick him, and he withheld information from him and made things appear differently. With his superior intellect, he manipulated Othello like a puppet. Manipulators are among us. Would you be able to tell if you were manipulated? WORK CITED BROCK, James Harry Ernest, Iago some Shakespearean Villians, New York, AMS Press, 1973 COE, Charles Norton, Shakespeares’s Villains, New York, AMS Press, 1972 GOLL, August, Criminal Types in Shakespeare, New York, Haskell House, 1966 NAZARE-AGA, Isabelle, Les Manipulateurs sont parmis nous: Qui sont-ils? Comment s’en protà ©ger?, Montreal, Les Éditions de L’Homme, 1997 SHAKESPEARE, William, Othello, New York, Washington Square Press, 1993 WEILGART, Wolfgang J. Shakespeare Pschognostic: Character Evolution and Transformation, AMS Press, 1972 â€Å"Jalousie Illusoir†, 2010, http://www.worldlingo.com/ma/enwiki/fr/Delusional_jealousy, consulted on November 9th 2010 How to cite How Does Iago Corrup Othello in Shakespear’s Othello, Papers

Literature review of Article on Gender Equality

Question: Discuss about the Literature review of an article on gender equality.? Answer: Introduction: The aim of the study is to carry out a critical evaluation of a number of journal articles. The topic selected for the particular study is Gender equality. Gender equality or gender egalitarianism is the view that determines the fact that everyone in the society should receive equal treatment without discriminating people based on their genders. The article by Nyberg et al. (2015) has been selected for conducting the literature review. In order to support the arguments put forwarded by the authors, several other articles will also be evaluated in the study. Interpretation and Analysis of Literature: Gender inequality remains a major barrier to the human development. There are many evidences when girls and women have made major strides but they have failed to gain gender equality. These disadvantages that the girls have to face, act as major source of inequality. In addition to this, women are discriminated in every aspects of life including health, education, labor market and even political representations (Verloo 2016). This situation has created a negative repercussion for the development in terms of their capabilities and curbs their freedom of choices as well. Inequality due to Gap in Income Level: In the provided reading, the main perspective of the argument was to explore objective career success among the men and women of Sweden. It has been commented that people with higher status in the society are benefitted with better health condition. It has been found that there is a gap between the income level of men and women of the country. Associating the financial condition with well being, it has been stated that the men are at a better state of health condition because their income in higher than women. In this respect, Malmusi et al. (2014) has also showed same response that the health condition varies between men and women and the main reason is the inequality in the income between the men and women. There are many evidences where it is evident that women are discriminated when it comes to health care. One of the key points that can be highlighted is that for the insurance premium as well, women have to pay higher than that of the men. Discriminations have been evident when it comes to expenditure of medicines that the women have to pay over men. Inequality in Pay-Scale Structure: Another important thing pointed out by Nyberg et al. (2015) is that there remains a lack of career opportunity among the women as well. Moreover, it has also been pointed out that women are paid lesser than that of the men for doing the same work. For reaching a particular conclusion, a qualitative analysis had been carried on among some women. It has been found that women are not preferred when it comes to promotion in their respective Organizations and if promoted, they do not get an equal hike in their salary as another person of opposite gender gets. Similar kind of response was observed reading Theorell et al. (2013) where the women are found to suffer more stress and pressure at their work place. This work pressure is a combined result of unequal pay scale or extra work that they have to do compare to men at work. There are many evidences where it has been evident that women have great strides at the workplace but still when it comes to inequalities and discrimination, women ha ve to suffer. Gender inequality at work has drawn attention of the government of countries like USA and UK (Branisa et al. 2013). Focus has been made to create a balance in life between men and women but there still remains certain sphere where the women have to suffer because of their gender. Inequality at the Work Place: Nyberg et al. (2015) also came up with the fact that the work done by women is not recognized well and they always remained underprivileged compare to men at the same work place. The expectancy levels from women always remain low because they are found to be inadequate and incompetent when it comes to their ability. It has been widely accepted that there remained gender inequality at the work place. Gender inequality still remained an issue that needs to be solved. There remains an unsolved problem and an imbalanced representation at the senior management at the work place (Branisa et al. 2013). The problem still remained unsolved problems and an imbalance in the pay scale as well as at the managerial representation (Yang and Aldrich 2014). There is plethora of interventions that an employer can choose from in order to redress the inequality at the work. Inequality and biasness has been evident at the time of recruitment as well. Recruitment process has also created a barrier among t he women to get the right place and position where they should be. Instead men get better position and a higher designation at the work place than women (Waldfogel 2013). In fact, certain issues have highlighted on the fact that when training is given to the employees of an organization, men are preferred over women when it comes to the ultimate selection process. Moving women from the employee position to the management position are almost negligible and to some extent, it is restricted (Waldfogel 2013). All these issues are perhaps creating such an environment at the work place that the women are finding it difficult to keep a balanced life. Conclusion: With the detailed discussion done on the inequality of gender, it has been evident that there still remained certain areas in social as well as political sphere where the women have to suffer just because of her gender. Such inequality has been persisting since a long time in spite of undertaking various measurements to increase the quality and equality of the life of female gender. Gender inequality has been a topic of discussion among many states and countries and positive approaches have been made to improve the condition of women but much has not been made in terms of improving the condition. The above made discussion has highlighted the major issues that women face or have to face in the contemporary situation. There is no doubt that there still persists some kind of imbalance between the men and women in social as well as political sphere that needs serious attention. References: Branisa, B., Klasen, S. and Ziegler, M., 2013. Gender inequality in social institutions and gendered development outcomes.World Development,45, pp.252-268. Malmusi, D., Vives, A., Benach, J., and Borrell, C. 2014. Gender inequalities in health: exploring the contribution of living conditions in the intersection of social class.Glob Health Action,7, 23189. Nyberg, A., Hanson, L.L.M., Leineweber, C. and Johansson, G., 2015. Do Predictors of Career Success Differ between Swedish Women and Men? Data from the Swedish Longitudinal Occupational Survey of Health (SLOSH).PloS one,10(10), p.e0140516. Theorell, T., Hammarstrm, A., Gustafsson, P. E., Hanson, L. M., Janlert, U., and Westerlund, H. 2013. Job strain and depressive symptoms in men and women: a prospective study of the working population in Sweden.Journal of epidemiology and community health, jech-2012. Verloo, M., 2016. Mainstreaming gender equality in Europe. A critical frame analysis approach.? ? ?,117(117), pp.11-34. Waldfogel, J., 2013. Feminist Economics: Then and Now-Gender Inequality and Wages.LERA Resources Demonstration. Yang, T. and Aldrich, H.E., 2014. Whos the boss? Explaining gender inequality in entrepreneurial teams.American Sociological Review, p. 207.

metallica free essay sample

Metallica, one of the greatest metal bands of the twentieth century. There 1991 album called Metallica or to most people its the black album. This album was more of a hard rock album unlike there past album ride the lightning. This album is known for the song â€Å"Enter Sandman† which was there most popular song on the album. â€Å"Enter Sandman† lyrics tell a story of a kid having a bad dream, this song I liked the most because it had a good sound to the instruments and vocals. I would recommend this album to any one that likes a little bit of soft rock songs like â€Å"Nothing Else Matters†. There are hard rock songs such as â€Å"Sad but True† and â€Å"Where Ever I May Roam† you might like those songs. I would give this album a five out of five because this album was a great mix of hard and soft rock. We will write a custom essay sample on metallica or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Metallica has a new album called death magnetic that came out in 2008. Metallica free essay sample All of the lyrics in the albums track list were written by James Hatfield and was produced by Fleming Rasmussen. Rasmussen was asked to produce this album because Of his work on his recent album with the Rainbows Difficult to Cure. In Master of Puppets, the basic rock instruments were used such as the electric guitar, the drums, the bass, vocals and some studio effects. On many of the albums that were sold, there had been placed a MARC explicit lyrics label on each album due to the explicit lyrics and content in the song damage, Inc. This is the only song in the album with cuss rods or explicit lyrics.Master of Puppets is the last album that you will hear Cliff Burton, the bassist, play in. Cliff Burton had ended up in a fatal bus crash in Sweden in September of 1986 while touring with the band for the album. We will write a custom essay sample on Metallica or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The band and Danish producer Fleming Rasmussen had also paid a tribute to their fellow bass player. The album was recorded between September 1, 1985 through December 27, 1985 at Sweet Silence Studios in Copenhagen, Denmark. When the album was finally finished, it came out 54 minutes and 46 second S. On the album Master of Puppets, the song Master of Puppets happens to e the most listened to song out of all the tracks.According to Gibson. Comas top 50 metal songs of all time, Master of puppets had taken the number one spot on the chart and also had been used by ESP. to promote the MASCARA Nationwide Series. The title track had also been used in the comedy film Old School with Will Farrell. Another interesting fact about the album is that a few of the songs such as Leper Messiah, Damage, Inc, and Battery had appeared on the music video games Guitar Hero and Rock Band. In the there can be many different meanings to each song, it just depends on owe a person interprets it individually.For example, in the title track Master of Puppets, the song is about how you can become addicted to something (drugs in this case) to the point where it ruins you and tears you apart. Another example is Welcome Home (Sanitarium), which is about a sane person who is locked in an insane asylum and turns insane because of the environment. Basically this song is about being locked in a mental prison. Anyways, in this album there are many messages to interpret in many different ways. The original album cover for Master of Puppets was painted by Don Vibrating in 1986.The cover of the album shows a graveyard with all the white tombstones shaped as crosses with white strings attached to each one of them all leading to the hands of the master of puppets. On one of the crosses there is a military helmet and on another there is an ID tag from one of the soldiers who had died in the war which relates to the music in the album. This album had sold well over 6 million certified copies in the US, it says in adumbrations. Net. On everyone of Broughams album art works, he is said to sign them in the bottom right corner. The two songs that have analyzed are Welcome Home (Sanitarium) and Disposable Heroes. Both of these songs are very interesting lyrically and are great songs to listen to. Welcome Home (Sanitarium) is about a perfectly sane person becomes trapped in his own thoughts and becomes insane. The cause of his insanity is the environment he is in which seems like a jail. This leads to his mind to accept that killing is a way to escape. Next Disposable Heroes is about soldiers going to war and how the band is against war and all about peace. It also talks about how the soldier accepts death and knows it as if its in front of him ready for it to happen at any time.For example Greeting death h?s yours to take away, the soldiers know that death is in their future. This song also relates to the military helmet and the ID tag on the crosses in the cover of the album. The band uses their songs to send out messages inside to their audiences who pay attention to their lyrics and take them to heart and mind. Metallic Master of Puppets was a very interesting and unique album to listen to. I thought that James Hatfield did a great job using metaphors and phrases to describe what was going on in the songs. He had also done a very good job in writing all of the songs overall.Although, in my opinion some songs were just to hard for me to understand. When actually took the time to review the lyrics is when started to understand the real meaning for some of the lyrics to the songs but, there are some songs that I do not understand what they are trying to say. Think the album art work is good and relates to the songs in the album. My favorite song in the album might have to be Welcome Home (Sanitarium). One more thing really liked about this album is the fact that they used the acoustic and rhythmic guitar to fade into their fast pace songs.

Choosing A Sample Of A Comparison Essay

Choosing A Sample Of A Comparison EssayIt is imperative to have a sample of a comparison essay. Even though it is a sample, it must still demonstrate how the essay works. There is nothing worse than writing the same essay over and then not having one that actually demonstrates how it works. In order to do this, you need to have several examples to work from so that you can pick the best one.Keep in mind that writing samples can be found by doing a search for them on the Internet. I can highly recommend having several examples because it will be easier to pick the one that you like. The more samples you have, the better the selection. Make sure that you research the company that offers these writing samples so that you can find them easily. Your research should include things such as their reputation, the amount of money they charge, and if they are going to provide you with samples as well.Of course samples of a comparison essay are very easy to use. You can use them to learn how to write such essays. One good tip that you can use is to write down some tips and a few problems so that you can compare it against some examples of other essays.You will find that you get better with practice. You should not worry about what some other student has written. It is all your opinion and you are the one writing the essay. Do not feel bad about that.If you are in an English class, then you may be asked to write an extra credit assignment that will consist of writing a comparison essay. It is your responsibility to be able to present your own opinions so that you can get credit for your hard work.When looking for writing samples, be sure to look at some samples of other essays that other students have written. This will help you determine if your own essay will be the one that you will end up writing. If you do not have anyone to help you, then you should look around for others who can help you out. That will save you time and money as well.All too often, students choose to write an essay based on what they have learned in their studies. They might want to write an essay because they want to make an impression on a professor, or they might want to write an essay to get extra credit.I know that you are not going to do either of those things, but you need to make sure that your essay is well researched and interesting. It should not just be your opinion, but your experiences as well.

response2 Example

Summary/response2 Example Summary/response2 – Coursework Example Summary Summary This paper will summarize and analyze the given articles. The paper will identify the theme and the relationship between articles. Furthermore, the paper will include response on the subject as well.SummaryAccording to the news article it has been told that the unsustainable growth of the prisons in the United States has forced the US attorney general to soften the strict obligatory sentencing relating drug offense. It has been noted that it costs around $80Billion every year to the US government to look after the overcrowded prisons. Furthermore, it was also revealed that the country has the highest number of prisoners. Compared to China, the US has a six times greater rate of incarceration. The attorney waived crime charges on non-violent drug offenses. These reforms are also supported by President Obama as well (Sanchez, 2013). ResponseThe theme of one article is banking and economy while the other one revolves around the prisons and economy of the United States. I n both the articles, it has been noticed that there is a relationship between the subject and economy of the country (Sanchez, 2013). Both the articles had illustrated that because of banking and increased number of prisoners the US economy had has suffered a lot. However, for the article by Associated Press on Citigroup highlights the reason of economic crisis while the article by Raf Sanchez on US drug sentencing has highlighted that the previous sentencing practices were affecting young African Americans. According to my opinion, both the authors have correctly brought light on these issues and have provided the reasons behind them. However, compared to US, China is not facing such issues. ReferenceSanchez, R. (2013, August 13). US to soften guidelines for drug sentences in face of US$80 billion a year costs and overcrowded prisons. Retrieved from nationalpost.com: http://news.nationalpost.com/2013/08/13/u-s-to-soften-guidelines-for-drug-sentences-in-face-of-us80-billion-a-year-c osts-and-overcrowded-prisons/

Grammar rules - Emphasis

Grammar rules Grammar rules Grammar sends many people into a panic, as they desperately try to recall what they learned in English lessons at school. But grammar doesnt have to be an impenetrable mass of rules and regulations. Breaking the English language down into bite-sized chunks and understanding the basic principles of grammar can really help you to improve your writing and make it clearer for others to understand. So here are a few basic tips to help you with grammar in your writing. 1. Parts of speech English can be complicated and its easy to get in a muddle. Heres a reminder of some of the languages parts of speech: A noun. This is a naming word to indicate someone or something. There are various types of noun: common nouns (cat, flower); proper nouns (Berlin, Andy Warhol); and collective nouns (group, team). A verb. This is most easily remembered as a doing or action word, for example, the boy eats a big bag of sweets. All sentences must contain a verb. An adjective. This is a word that describes a noun. There are different sorts of adjective: descriptive adjectives (a brilliant party, a sunny day); numerical adjectives (seven apples, five gold rings); and possessive adjectives (my hat, your coat). An adverb. There are several categories of adverb: adverbs of manner (he ran quickly, she walked slowly); adverbs of time (I hope that Gran will visit us soon); and adverbs of place (please sign here). In each instance, the adverb tells us more about the verb. 2. Match your subjects and verbs Make sure that the verb you use always matches your subject. Consider the following sentence: A bunch of grapes cost 1.99. This is incorrect, because the subject is a bunch of grapes, so you should treat it as singular. The correct version would be: A bunch of grapes costs 1.99. 3. Make words in a list match When listing items in a sentence, make sure that the words you use complement each other. Consider the sentence: You can get to sunny Scunthorpe by train, car or cycling. Here two nouns (train and car) have been mixed with a verb (cycling). It would be better to say: You can get to sunny Scunthorpe by train, car or bicycle. You can find out more about grammar on an Emphasis in-company or public course. Or you can email us to find out how we can help your organisation.

Management Journal Essay Example | Topics and Well Written Essays - 1000 words - 1

Management Journal - Essay Example Kelvin said that he was not aware because he was a new employee at the company. I told him to always ensure that he plan his time effectively to ensure that he perform significant tasks before others. I advised the employee because I knew that effective management of time leads to the success of the business (Koontz and Weihrich 67). I also talked to the employee because I knew that it was my role as the manager of the company. September 3 2013 Management is a challenging task because it involves balancing work and family functions and time. I thought about this statement when I discovered that today was the twentieth anniversary of the company, and at the same time, it was my first born’s birthday. I was stressed while thinking of how I would ensure that I attend the two functions and satisfy the company and my family. I had to think of an effective plan that would help me manage the day’s time efficiently, although it was a bit challenging. I thought of a plan where I would attend the company’s function in the day as my family prepares for an evening party for my son. The plan was successful, and both teams were satisfied with my attendance. I played the role of a father and manager at the same time. Before I was promoted to be a manager, I had heard supervisors talking about how they had difficulties balancing time and work. Today I followed their advice, and I found out that balancing work and family increases satisfaction, and it reduces stress (Koontz and Weihrich 195). September 4 2013 Today, I had a conference with all employees, and the aim of the meeting was to remind them the goals of the company. I have always known that communication is vital in the management because it informs workers about the goals to pursue, the tasks to undertake, and the techniques to utilize (Koontz and Weihrich 199). I have also read numerous books that argue that managers must possess effective communication skills so that they can lead others in the right direction. This was my first day to talk to the employees as a manager, and I had to ensure that I pass the company’s message clearly. Before attending the meeting, I read a book that pointed out various forms of communication. The book argued that communications between managers and employees takes place through bottom-up or top-down approaches. Top-down involves supervisors passing information to employees at lower levels; company objectives may be communicated using this approach. Bottom-up technique is one where employees speak to managers often when giving feedback (Koontz and Weihrich 100). The readings gave me confidence, and I attended the conference and passed the information to workers clearly. The day was successful, and my confidence increased when other managers said that I had excellent communication skills. September 5 2013 Today, one of my employees approached me and said that she had a problem coping with her workmate who was uncooperative. The two perf orm their tasks in one office where they file company documents. Mary, the employee who approached me said that Annette spent most of her time on the phone instead of working. This increases Mary’s workload, and she leaves the office late every day. I confirmed this from other workers, and I also checked the register and found out that Mary leaves the office three hours after the closing time. I knew this was a problem, and I had to solve it intelligently to ensure that the two get satisfied with the solution (Koontz and Weihr

New York Project Essay Example | Topics and Well Written Essays - 750 words - 4

New York Project - Essay Example The 12 friends come from the city of Los Angeles and wish to go to the city of New York by flight. If they fly to New York using Delta Airlines they will have to pay a one way price of 33 US Dollars. For all of them, they will have to pay a total of 792 US Dollars for both journeys. The first show that they plan on seeing is a Broadway musical by the name, â€Å"After Midnight†. This musical celebrates the exuberance and glamour of Harlem’s Golden Age. It consists of Harlem’s most popular nightclub. The musical is performed by exceptional jazz at Lincoln Center All-Stars. This is an orchestra consisting of 17 world-class musicians carefully selected by Wynton Marsalis. Marsalis is a 9-time Grammy Award winner. The musical includes songs by Cab Calloway, Harold Arlen, Duke Ellington and their contemporaries. The stage performances and dances make it even more captivating. Charles Isherwood of the New York Times calls â€Å"After Midnight†, â€Å"a depiction of time-traveling back to the heyday of the Cotton Club as it moves through more than 25 songs from the jazz era.† Marilyn Stasio of broadways also describes it as, â€Å"stylized treatment of a midnight floorshow at a 1930s jazz club is gorgeously designed to showcase roof -raising performances from top-flight talent†. Watching the musical from the mid mezzanine section they will have to part ways with 70 US Dollars each. The second show that they plan on seeing is a play by the name, â€Å"The Accidental Pervert†. This play is a one man show, which tells a story about a boy whose journey into manhood begins when he starts watching his father’s X-rated videos. The videos eventually became an ever-present part of the boy’s life. The play depicts the videos to be having dirty contents with no redeeming value. The boy eventually finds redemption from the mess he put himself in when the gets a different perspective of life. This

Cross Culture Understanding And Tourism Cultural Studies Essay

Cross Culture Understanding And Tourism Cultural Studies Essay Analyse three important aspects of cross-cultural understanding which affect tourism. No one would challenge the fact that tourism has become an international phenomenon of global consequence (Uysal, 1994, p.123). The internationalization of the tourism industry is complex and wide ranging. It is a type of cross-cultural communication and understanding. For instance, tourists who come from all over the world may have numerous encounters while visiting a destination such as accommodation, transportation, attractions and catering. Meanwhile, the tourism industry has to organize tourism resources well and also fulfil tourists satisfaction (David Jackie, 2009, p.139) from their different cultural backgrounds. Cross-cultural communication is based on languages, customs, foods and religions. Thesis Statement: Cross-cultural communication has lead to the growth of the tourism market in the last decades and is booming in 21st century. International tourism is typical cross-cultural communication. Millions of people have encountered other cultures primarily to pursue a vacation (Kim, 2001, para. 3) to experience various cultures and customs. Purpose Statement: The purpose of this essay is to analyse three important aspects of cross cultural understanding which affect global tourism in terms of communication methods, foods as well as religions. First, it will outline the most important aspects of cross-cultural understanding in the industry. Secondly, it will explain why they are important for both tourists and hosts by providing some examples. Finally, some suggestions will be given for running a successful global tourism business. Body A Language 1. Language is very important for a tourist Language is the code (Wagen, 1997, p 41) in cross-cultural communication, it is important in tourism for both tourists and hosts because it is the means by which meaning is constructed between them. It has been viewed as exchange of information and cultural differences. If they cant understand the same language the tourist experience will be unsatisfactory. Furthermore, the hosts wont be able to provide a quality product or experience and their business and reputation depend on doing so. For example, if we look at the experience of Japanese tourists who visit Australia, they need to be able to get accurate information for visiting the places they want to see. Since the tourists speak Japanese and the people in the tourism destination speak English, it can give rise to problems in terms of no communication and misunderstanding. In addition to that, other situations where language is very important to tourists are accidents or crises of some kind like losing a wallet or getting lost i n the situation of tourists cannot understand the information which have been provided on the signage (du Cros, 2007. p. 228) as well as they cant communicate in English. These can be very serious matters. 2. Language is an important factor that tourism hosts have to take into consideration. In order to obtain cross-cultural understanding and make tourism satisfied with their overseas travel. Language is an important factor. Tourism hosts should be aware of tourists language habit and tradition. In the case of Japanese visit Australia, it is important that the host enterprises provide some on-site interpretation (du Cros, 2007, p. 235) service. They basically tend to remove the confusion between difference languages. In addition, to provide some Japanese information, for example, Japanese version of warning, introduction as well as catalogues will help them to understand. In case of some accidents will happen during the traveling. The travel agency also needs to provide some Japanese document which including information of embassy, police offices and other organizations. On the other hand, despite Japanese tourists can speak English while they travel in Australia, their way of expression is different from native speakers. Therefore, to understand Japaneses verbal communication skills and traditions plays a significant role in tourism industry especially for hosts. FitzGerald (1998, p.23) provided the fact that the way of answer the questions in terms of you dont, do you we cant, can we. To native speaker, their answer is No when they agree with this sentence. But Japanese peoples answer is yes, which is opposite meaning to English speakers. It is because there is no rhetorical question in Japanese dialogue. The answer is following the question in Japanese whereas it is in according to the fact in English. Therefore, it is better to avoid offering these sorts of questions to Japanese, otherwise it will lead to misunderstanding. Furthermore, Japanese people who travel in Australia would give their opinion by translate Japanese to English directly, whic h means the style (FitzGerald, 1998, p.23) of answer is different from English. According to FitzGerald, when Japanese give feedback, they prefer repeat yes instead of OK or I got it. Those are examples of different verbal communication in Japanese and English which make hosts to take into consideration when they provide tourism service. Non-verbal communication Non-verbal communication is very important for a tourist. According to Reisinger (2002, p.31) Cross-cultural difference are not only refers to verbal communication, but also existed in all sorts of human activities between foreigner tourist and local hosts. Non-verbal behavior is a significant element for a tourist because it is easier to be noticed and understood than verbal communication. Mehrabian(as cited in wagen,1997, p43)state that less than 10% of the message is communicated by words recording, as twice as much that of the message expressed by languages and 70% of through non-verbal language in terms of posture, gesture and facial expression. What is more, the behaviors of greeting, formality as well as body touching are important means of non-verbal communication which are reflected by tourists. Non-verbal communication is an important factor that tourism hosts have to take into consideration. Likewise the verbal communication which is indispensable, to tourism hosts, non-verbal communication is important as well. According to FitzGerald (1998, p.xii), for the Asian people who visit Australia, the hosts should be aware of their sensibilities of their own cultures and customs. For instance, for Chinese people, there is not too much body touch between male and female. They prefer to smile and pad without touching. The only touching is hands shaking while first meet which is widely being accepted recently. Therefore, hosts should avoid much body contact. This names cards which be considered the representation of persons face should fully aware by hosts. It is suggested to pass them with two hands as well as accept them in a similar fashion (FitzGerald, 1998, p.63) when give name cards to customers. Meanwhile, they should be accepted respectfully and reading carefully the names cards of their customers, which is a sort of etiquette in international business. It is better, espe cially for tourists who from Japan and Korea, to pass and receive all the objects to use both hands. What is more, gesture in terms of a kind of body language can easily be identified by hosts. People from different cultural backgrounds have different speculations of body languages. Several examples are provided below which present the different features of body languages of Asian people. Table 1.1 Body Language gestures from around Asia. (Van der Wagen, L, 1997) China Sucking air through the teeth occurs when something is surprising or difficult. In China it is best to change the request to avoid the embarrassment of having to say No. The host always has his back to the door while the chief guset faces the door. To beckon someone, the palm faces downward and the fingers are moved in a scratching motion. Bones are often left alongside the dish. When finished eating the custom is to place the chopsticks parallel across the bowl. Indonesia Indonesians rarely disagree in public and will laugh together and hold them over their heads. Guests do not drink until the host begins. Where the table is large, rapping the knuckles on the table is a form of restaurants people may share tables. Japan Direct eye contact can be seen as intimidating. Bowing in greeting is customary. Waving the hand in front of the face signals I dont knowor I dont understand. A waiters attention is attracted by catching his eye and dipping the head. Listening without interruption is polite. A Japanese person wearing a mask in public probably has a cold. Korea The Western gesture for come here is only used for dogs. To beckon someone in Korea the arm is extended, palm down and a scratching motion is used. Drunkenness is quickly forgiven. Thailand Showing the soles of the feet or pointing with a foot is insulting as the foot is seen as the dirtiest part of the body. The head is the most sacred part of the body, and children should not be patted on the head. The left hand is unclear and is not used to pass objects or food. (Source: Van der Wagen. 2002, p. 44) Food What food means to a tourist. Food is considered as an aspect of cultures. It is important to tourist because they can experiment the local culture via taste local food. There are increasing recognition that tourist who travel around are aim to enjoy the variety of local cuisine, drink as well as snack. Sim (as cited in Urry Wang, 2007.p.328) argued that tourists is going to obtain typical signs which representative a place that comfort to their own expectations, foods and drinks would be a good example. Therefore, tourists are likely to perchance regional specialities (Sim as cited in Urry Wang, 2007.p.328) as well as sit in the famous local restaurant to enjoy the authentic local food. Meanwhile,it also be argued that the to develop the local catering is a kind of connection between consumers and the local residents. Tourists are looking for commodities that can give them an insight into the nature of a place and people who living there. so that they will encounter the dialect, customs, life styles and people s dressing code while they visit these restaurants, which is a powerful part of an integrated tourism experience. Local specialities as a sort of souvenir are different from other objects, for example, tickets. They provide both visible memories (local words, pictures) as well as sensory memories (Sim as cited in Urry Wang, 2007.p.328) which has stronger association with the local culture they have experienced. How a tourism host has to think about food for tourists. Sims (2009, p.328) states that to designing and provide high-quality catering or distinctive local food products is one way of promote local food brands. Normally, there are several famous local restaurant can be introduced to tourists during their travelling. Hosts should be aware of successful tourism management have to develop a range of local catering service which can be distinguished from other tourism management and attract a constantly visitors streaming. Meanwhile, it is vital for hosts to master the food restrictions which belong to different customers. In the Christian calendar, two significant events must be remembered: Easter day and Christmas. Both of them are the commemoration of Jesus Christ whereas Ester day follows a lunar cycle (FitzGerald, 1998, p. 7) and Christmas day is fixed every year. Despite of some of them would avoid red meat on Friday there is no particular food restriction for Christines. Some special food should be prepared and provided in Hotel and res taurant on Easter day and big family Christmas feast (FitzGerald, 1998, p.7). In addition, most of the Buddhists are vegetarian because vegetarianism (FitzGerald, 1998, p.13) is the single restriction for food of this religion. This issue should be noticed by people who running international tourism business. Religions and Philosophies How these religion might affect tourists. Religions and Philosophies take part into a significant role in the human beings civilization and history. Every religion has its own characteristic and philosophy. Therefore, for tourists who going to make an overseas traveling, they may encounter situations which is different from or even disobey with their believing. Meanwhile, tourists who have their own religion will always be obedient. No matter which area they were or they will be. The religious philosophies and behaviors would never be changed. For example, in Islam, all the individuals behaviors have been controlled in their social, economic and political lives. They are not allowed to eat pork, animals blood and even have one month for Ramadan (FitzGerald, 1998, p.4) which demands all the Muslims be fast during the daytime. The Muslim women who wear hijab might not suit to go to the beach while they are travelling. Some potential dangers would be existed participate some recreation activities as well. How a tourism host has to cater for religious differences As FitzGerald (1998) has indicated that to understand the different religions and their philosophies would improved the communication in global tourism industry for both tourists and host. What is more, to show respect to each religion and offer special tread for them are very important for hosts. As it mentioned before, Muslins have to worship five times every week. As a result, hosts need to make sure they know where the mosque is or even provide a quiet corner for them to complete the mission. Buddhism, which is a pan-Asian religion and philosophy (FitzGerald, 1998, p. 11) has affected in the field of spirit, social life and national culture in the eastern world over a long period of time. Buddhists are promising not to kill or harm any living things. Undertaking family and sex loyalty and refraining from get something which doesnt belong to them. Conclusion: In conclusion, it is clear that cross-cultural communication and understanding not only affect to international tourists, but are also important to the hosts who running the global tourism business in the field of language, customs, food and regions. Essentially, tourists who travel in the intercultural environment can be affected by the differences between other cultures and their own. Meanwhile, the different languages give rise to some misunderstanding or even non-communication. Therefore, the hosts must be aware of these cultural differences such as different languages, different non-verbal communication and different religions they have. Above all, in order to eliminate the communication problems and maintain an atmosphere of peace and enjoyment in international tourism circumstances. It is necessary for hosts to take these into consideration in this industry by supply interpreters, foreigner information translation. People who work in this industry must know very well about the characteristics of different customs and religions, which can help to avoid cultural conflicts. In addition to that, tourism business owners have to provide ideal service which can give international tourists a unique local cultural experience. Meanwhile, customers cultures and customs should be respected. The cross-cultural understanding in global industry may never be completely taken into consideration by hosts, however, further studies to identify potential problems and solutions, as well as an improvement in cross cultural communication for global tourism industry, should result in a better understanding and more enjoyable experiences for both hosts and tourists.

Separation, Divorce & Annulment

SEPARATION, DIVORCE & ANNULMENT Introduction When two people are in a relationship they are usually in it forever. Unfortunately, it isn’t always the case and as you will learn in this unit, there are many things that could potentially be blamed for the breakdown of such relationships. This topic takes you into the world of divorce which is never an easy thing for any couple and if there are children involved (and there usually are); it makes the experience even worse. Some couples split amicably while for others the parting can drag on in what could seem like forever where the accusations and blame is often hurled from one party to another.In many countries, there has been a shift towards ‘no fault’ divorce. A no fault divorce is divorce in which the dissolution of a marriage does not require fault of either party to be shown, or the requirement of any evidentiary proceedings to take place. So either party may request a divorce despite the objections of the other party. No fault divorce systems are where the law provides for only one ground for divorce – this is that the marriage has broken down irretrievably (see example, s30(1) Family Law Act, Fiji).This does not necessarily mean that both parties to the marriage were equally blameless for the breakdown in the relationship but it does recognise that both may have contributed to that breakdown and that blame and accusation can aggravate what is likely to already be an unhappy and often bitter situation. Accusations and recriminations do not help this and may be particularly damaging for any children of the marriage, who, despite whatever the feelings of their parents, still need to have a mother and father.While marriage remains an important cornerstone for the stability of society and social ordering, the law allows divorce and provides a framework both for that divorce and for the consequences of that change of status especially as regards any children of the marriage and any prop erty interests which have arisen due to the marriage. 1. Ground s for Di v or c e Grounds for divorce are statutorily provided for throughout the region. They include: i. adultery ii. desertion iii. refusal to consummate iv. cruelty v. habitual drunkenness or habitual intoxication vi. onvictions for various criminal acts vii. failure to financially support the petitioner viii. failure to comply with a decree for the restitution of conjugal rights ix. being of unsound mine x. living apart for five years from the respondent with no intention of cohabiting xi. Presumed dead. LW310 Family law 4. 6 In Tuvalu, unless one party to a marriage has wilfully refused to consummate it, or the marriage was induced by fraud, duress or mistake, the sole ground for divorce is that the marriage has broken down completely (Matrimonial Proceedings Act [Cap 21] (Tuvalu) section 9).Evidence which may be accepted by the court to show that the marriage has broken down includes adultery, desertion, cruelty, being of unsound mind or if, in the circumstances, it would be unreasonable to expect one party to continue in the marriage. Whatever the evidence, however, the court must determine whether or not the marriage has completely broken down. A more restrictive approach is taken by Nauru where the court must find that the marriage has broken down irretrievably and it may only do so on one of four grounds.These grounds are desertion, separation for two years with consent of both parties or separation for five years and certain behaviour. These grounds need to be proved or parties need to fulfil strict conditions. The conditions relate to: †¢ living apart, †¢ attendance at court each month for six months after presentation of the petition, †¢ consistent and voluntary statements requesting the marriage to be dissolved and †¢ attempts by the court to promote reconciliation (Matrimonial Causes Act 1973 (Nauru) ss 10 and 12).Tonga prescribes eight matrimonial offences alth ough, with consent, the parties may also divorce after two years of separation. READ s 3 Divorce Act [Cap 29] (Tonga) There are only three grounds for dissolution of marriage in Tokelau – adultery, cruelty and three years of living apart (Divorce Regulations 1987 Reg 3). In Kiribati, fault grounds predominate. I-Kiribati parties may divorce if the court finds that their temperaments are incompatible (Native Divorce Act [Cap 60] s 4).However, the Matrimonial Causes Act 1950 (UK) which applies to other races in Kiribati and to foreigners in Solomon Islands, reinforces the fault based position by insisting on the blameless character of the petitioner and the fault of the respondent. In Fiji, the Family Law Act provides only one ground for divorce and that is irretrievable breakdown (s 30). This marks a shift to ‘no fault’ divorce, although often one of the various ‘matrimonial offences’ which may be relied on as a grounds for divorce elsewhere may have contributed to the irretrievable breakdown of the marriage – for example, adultery by one of the spouses.However a variety of lesser ‘fault’ may have led to the irretrievable breakdown of the marriage. What the court is looking for is evidence of conduct which makes it impossible for the two parties to continue to live as husband and wife in close proximity to each other and sharing the same home, resources and living space. I. Adultery Adultery is one of the most common grounds of divorce where it is still necessary to show fault.For the purposes of obtaining a divorce on the ground of adultery in fault based jurisdictions, a petitioner must prove that the respondent engaged in voluntary sexual intercourse with another person of the opposite sex during the subsistence of the marriage (Coffey v Coffey [1989] P 169). All jurisdictions except for Fiji, Nauru and Tuvalu list adultery as a ground for divorce. READ s3 (1) (a) Divorce Act [Cap 29] (Tonga) In Tuvalu adu ltery, if proved, is prescribed as evidence which a court may accept as causing the marriage to completely break down.READ s 9(a) Matrimonial Proceedings Act [Cap 21] (Tuvalu) The fact of adultery must be proved to the satisfaction of the court although the required standard of proof is unclear. In Elisara v Elisara [1994] WSSC 14 the proof consisted of testimony of the petitioner and her sister that they had found the co-respondent â€Å"half dressed inside the matrimonial home† as well as the respondent’s admission. Chief Justice Sapolu recited the facts as follows; „The petitioner, the wife, and the respondent, the husband, are a married couple having been married on 5 January 1980.In the first quarter of 1993, the petitioner was under suspicion that her husband, the respondent, was having an affair with the co-respondent. The respondent was director of the Department of Lands and Environment until near the end of 1992. The co-respondent was a secretary in the same department. Due to her suspicions, the petitioner and her cousins kept watch of the respondent? s whereabouts on the nights that the petitioner and the respondent were not together. Then one night in the beginning of April 1993, the petitioner asked the respondent to drop her off at her family at Savalalo.Not very long after the petitioner was dropped off, she headed back with her sister and cousins to their matrimonial home at Waivaseuta. When they arrived at Vaivase-uta the lights downstairs of the matrimonial home were on but not the lights upstairs. The respondent came out of the house and asked the petitioner as to why she was there. The petitioner gave the excuse that she was there to look for a parcel. She searched every bedroom in the house and found the co-respondent in one of the bedrooms half-naked. She told the respondent this is the last time you will see me again in this house and then left.The petitioner? s sister also testified that she saw the co-respondent ha lf dressed inside the matrimonial home at Vaivase-uta on the same night. LW310 Family law 4. 8 In his evidence, the respondent admits having committed adultery with the co-respondent. He says he has never denied to his wife, the petitioner, that he had committed adultery with the co-respondent. The corespondent did not appear to give evidence. On this evidence, I find that the ground of adultery alleged in the petition had been established. Accordingly a decree is granted to dissolve the marriage of the petitioner to the respondent.?However, in Bhagmati & Another v Ishri Prasad [1974] 20 FLR 75, the Court dismissed an appeal by a wife against an order for dissolution of the marriage on the basis that admissions made by her were not voluntary. Mr. Justice Bodilly stated that: ‘The Court must have sufficient evidence before it to be reasonably satisfied. I think that it is clear that a court would not be reasonably satisfied upon a mere balance of probability, on the other hand I do not think that the standard of proof required is as high as that in criminal cases, namely beyond any reasonable doubt. It lies somewhere between the two?. READ THE CASE NOWProving adultery can be difficult and may depend on circumstantial evidence. Read the case of Sugar v Fatafeti [1993] TOSC 2 for an illustration of this. A fraudulent secret understanding between the parties – collusion – is also one of the discretionary bars available to some courts in the region. READ s 11 (2) Divorce Act [Cap 29] (Tonga) Condonation or connivance may also act as a bar to the relief sought by the petitioner, whilst forgiveness by the petitioner provides the respondent with a defence in the Marshall Islands, provided that the forgiving party is treated with â€Å"conjugal kindness† (26 MIRC 1 s17).See the Vanuatu case of Ilaisa v Ilaisa [1998] VUSC 16 where the question of condonation is considered. Adulterers must be joined as co-respondents in proceedings for divorce on the basis of adultery in most jurisdictions unless they are excused by the Court on special grounds. See Cook Islands Matrimonial Proceedings Act 1963 (NZ) s 22; Samoa Divorce and Matrimonial Causes Ordinance 1961 s 11; Kiribati and Solomon Islands Matrimonial Causes Act 1950 (UK) s 3 and Vanuatu Matrimonial Causes Act [Cap 192] s17. In Niue this is at the discretion of the court ((NZ) Niue Act 1966 s537.READ s 11 Divorce and Matrimonial Causes Ordinance, 1961 (Samoa) Proceedings against co-respondents may be dismissed by the Court if there is insufficient evidence against them. See for example, Samoa s. 10. LW310 Family law 4. 9 READ s 6 Divorce Act [Cap 29] (Tonga) In some countries petitioners have a right to claim damages against corespondents. See for example, Vanuatu, Solomon Islands and Kiribati. The Solomon Island and Vanuatu Acts provide that a petitioner relying on adultery as a ground for divorce may claim damages from any person.The amount of damages which may be clai med against co-respondents is prescribed in Tonga. READ s. 13 Divorce Act, 1927 (Tonga) In Cook Islands, Vanuatu and Tonga the courts may direct the manner in which such damages are to be paid or applied and the sex of the petitioner or respondent is irrelevant. However, only petitioner husbands in the Solomon Islands and non i-Kiribati in Kiribati may claim damages in adultery cases. The categorisation and amount of such damages, which are not specified in the Acts, (except in Tonga) has been the subject of some judicial concern.In Tonga where the amount claimed is specified, the court found in ‘Afa v Tali & Sika [1990] Tonga LR 185 that the maximum amount of damages should only be awarded where it was shown on the balance of probabilities that the conduct of the co-respondent brought about the breakdown of the marriage by, for example, seducing or enticing away the respondent. Further, damages were to be based on- (a) The actual value of the wife (sic) (in terms of money and companionship); and (b) Compensation for injury to feelings, honour and family life. Damages are measured as compensation and not to punish or make an example of the Co-respondent.This idea of damages as compensation rather than punishment was elaborated further in Lamatau v Mau [1991] TOSC 3. It has been indicated however that the award of damages is becoming less common and that the courts are reluctant to allow a change of claim to include damages – see Mamata v „Akolo [2001] TOSC 47. The Vanuatu case of Banga v Waiwo is further illustrative of the difficulties faced by courts in the region when interpreting legislation derived from colonial sources whilst attempting at the same time to acknowledge custom law and respond to local social conditions.This matter originated in the Senior Magistrates Court where the petitioner gave evidence that customary meetings had been held with regard to the marital dispute. As a result of these meetings the chiefs decided that the husband was to pay 20,000 vatu to the co-respondent’s husband and the co-respondent was to pay the wife 5,000 vatu and two pieces of calico. The petitioner was also to pay the co-respondent 5,000 vatu because she had â€Å"insulted† the co-respondent. Having refused to accept this decision, the petitioner approached the Court for a divorce and claimed 100,000 vatu damages against the co-respondent.The solicitor for the co-respondent argued that the sum claimed was excessive and amounted to punitive damages. Reference was made to the Matrimonial Causes Act 1965 (UK) on which the Vanuatu Act is based. In the UK, it was argued, damages are awarded on a compensatory basis only and this should also be the approach of the law in Vanuatu. The amount awarded by the Chiefs, namely 5,000 vatu, was submitted as being appropriate as compensation â€Å"for the loss of the Husband (sic). â€Å"On behalf of the petitioner it was submitted that section 17 (1) of the Act should be in terpreted according to the intention of Parliament. That section states that; †¢ A petitioner may on a petition for divorce claim damages from any person on the ground of adultery with the respondent. † †¢ It was also contended that â€Å"adultery is a serious offence in Vanuatu communities and that punitive damages are often given for adultery which show clearly that Vanuatu local circumstances are different from those of the United Kingdom.The Senior Magistrate (then) considered the issue of the interpretation of section 17 of the Act and referred to the rules in Heydon? s case (1584) as restated in Re Macmillion v Dent (1907) 1 Ch 120, Brett v Brett (1826) 2 D and s 8 of the Vanuatu Interpretation Act CAP 132. In determining the intention of parliament the Senior Magistrate found circumstances in Vanuatu to be quite different from those in the United Kingdom and the Acts themselves to differ in important respects. Unlike the position in the UK Act, which allows o nly a petitioning husband to claim damages, the Vanuatu Act is not so limited.In comparing the UK and Vanuatu jurisdictions, it was noted that in Vanuatu the law recognises civil, religious and custom marriages and customary law, pursuant to Article 95(3) of the Constitution. Further, because adultery is considered a serious offence on the basis of custom, ‘any damages claimed by the Petitioner against the Co-Respondent should be awarded in accordance with customary law. ’ The Senior Magistrate did not categorise the type of damages to be awarded. He found in favour of the petitioner with regard to the amount of damages, however, stating that, „†¦ 00,000 Vatu damages claimed against the Co-Respondent is not excessive and it should be awarded to the Petitioner in accordance with customary law. ’ The matter then went on appeal to the Supreme Court of the Republic of Vanuatu where Chief Justice Vaudin d’Imecourt held that, whilst exemplary damages could be awarded in an appropriate case, no evidence justifying such an award had been presented to the court. His Honour considered that custom law only LW310 Family law 4. 11 applied where no other law was in force. The Court also found that custom law is not uniform in Vanuatu and; Although it is conceivable that there might not be a need for strict rules regarding the obtaining of evidence of a particular custom if and when the need arises to establish a particular custom, evidence must, nevertheless, be obtained and a clear custom must be established. ’ READ Waiwo v Waiwo [1996] VUMC 1 and Banga v Waiwo [1996] VUSC 5 In Solomon Islands and Kiribati where UK Acts still apply, damages for adultery may be claimed by petitioner husbands. Where damages are not available the court may order an adulterer to pay costs. S t u d y T a s k 1 CONSIDER THE FOLLOWING QUESTIONSAdultery and Divorce 1. Do you think it is sufficient for the petitioner to simply show that the respondent ha s committed adultery OR that the respondent has committed adultery AND ALSO that the petitioner finds it intolerable to live with the respondent? 2. If it is sufficient only to show that the respondent has committed adultery is one incident of adultery sufficient? 3. To what extent should the court investigate the claim? If the petitioner files an affidavit stating he or she believes the respondent to have to have committed adultery is that sufficient? . What does adultery as a ground for divorce which is frequently relied on tells us a) about marriage b) about people? 5. Should it make any difference to a divorce petition if the petitioner has also committed adultery? 6. Is the adultery of a woman more serious than that of a man? If yes why? 7. If the ground for divorce is irretrievable breakdown or final breakdown of a marriage and the matrimonial fault relied on is adultery, should this be viewed more gravely than other matrimonial offences such as cruelty, habitual drunkenness, or desertion? . Could adultery be claimed as the ground for divorce even if in fact it is not this but other factors which have led to the irretrievable breakdown of the marriage? 9. To what extent should the law of divorce be used to punish adultery? 10. What is the advantage/disadvantage of joining a co-respondent to adultery in a divorce action? 11. Should a petitioner be able to claim damages from more than one corespondent? What are damages for in such cases? 12.Would it make any difference if the respondent had promised to marry the coLW310 Family law 4. 12 respondent? 13. Should a co-respondent ask if the respondent is married before having intercourse with him or her? 14. Should it make a difference – in law – if the co-respondent is married or not? 15. Is adultery a) unlawful b) immoral c) a fact which may be evidence of the breakdown of a marriage? 16. Should any consideration be given to the fact that there are children born from the adulterous union? II. De sertionIn Tuvalu and Nauru the sole ground upon which a petition for divorce may be presented is that the marriage has â€Å"completely broken down† (Matrimonial Proceedings Act Tuvalu s 9(1) and â€Å"broken down irretrievably†(Matrimonial Causes Act 1973 s 8 Nauru) respectively. In Tuvalu, desertion â€Å"without reasonable cause† (s. 9(2)(b) may be accepted as evidence of marriage breakdown whilst in Nauru it is one of the grounds which, if proved, can lead to a finding that the marriage has broken down irretrievably. (s 9 (1)(a)(ii) Desertion is not a ground for divorce in Tokelau.READ ss 9(1) and 9 (2)(b) Matrimonial Proceedings Act [Cap 21] (Tuvalu) The applicable provisions in Kiribati, (Native Divorce Ordinance s 4(b) and Matrimonial Causes Act (UK) 1950 s 1(b)) Niue ((NZ) Niue Act 1966 s 534(3)(c)) Solomon Islands (The Islanders Divorce Act [Cap 48] S5(1)(b) and Matrimonial Causes Act 1950 (UK. ) s 1(b)) and Vanuatu ( Matrimonial Causes Act [Cap 192] s 5(a)(ii)) state that the respondent must have deserted the petitioner without just cause (the wording in the Kiribati and Solomon Islands legislation is â€Å"without cause†) for at least three years.In the Cook Islands and Nauru the period is two years prior to filing the petition ( Matrimonial Proceedings Act, 1963 (NZ) s 21 (c) and Matrimonial Causes Act 1973 ss 9(1)(ii), 12 (3). 54) Wilful desertion is statutorily provided for in Cook Islands (Matrimonial Proceedings Act, 1963 (NZ) s 21 (c)); Marshall Islands (26 MIRC 1 s 15 (c)); Samoa (Divorce and Matrimonial Causes Ordinance 1961 s 7(1)(b)) and Tonga (The Divorce Act [Cap 29] s 3(1)(c)). LW310 Family law 4. 13The Marshall Islands Act prescribes a period of not less than one year before wilful desertion may be alleged, Samoa prescribes three years and the other jurisdictions prescribe two years. READ s 7(1) (b) Divorce and Matrimonial Causes Ordinance, 1961(Samoa) There appears to be no difference in law between wilful desertion and desertion as in all cases the burden is on the petitioner to show that throughout the statutory period the desertion subsisted without cause. A distinction can be made however between desertion and constructive desertion.Facts presented to the court must show that the respondent intended to leave the marriage and that the desertion was against the will of the petitioner. If the behaviour of one party to the marriage causes the other to leave the matrimonial home then constructive desertion may be argued. Cook Islands also allow desertion to continue notwithstanding that during the period of the desertion the deserting party becomes â€Å"incapable of forming or having an intention to continue the desertion† (Matrimonial Proceedings Act, 1963 (NZ) s 24)A review of desertion as a ground for divorce can be found in the Solomon Island case of Kikolo v Aberam [2002] SBHC 28. In the Fiji case of Kistamma v Sarojini [1977] 23 FLR 86, desertion was not made out because the respondent was found to have made a genuine offer to return to the marriage. See also Ledua v Uluiborotu [1994] FJHC 182 and compare Peck v Peck [1993] FJHC 34 There may be some confusion between desertion as a ground for divorce and separation. This was considered in the case of Peck v Peck [1993] FJHC 34 III. Failure to Consummate the MarriageThe issue as to whether or not the marriage has been consummated is dealt with in some jurisdictions as a ground for divorce and in others as rendering the marriage voidable. The latter approach is taken by Cook Islands (Matrimonial Proceedings Act, 1963(NZ) s 18 (2)(a)); Nauru (Matrimonial Causes Act 1973 s 22 (e)); Samoa (Divorce and Matrimonial Causes Ordinance 1961 s 9(3)(a)); Solomon Islands (The Islanders Divorce Act [Cap 48] s13 (1)(a) and Matrimonial Causes Act 1950 (UK. ) s 8 (1)(a)) and Vanuatu (Matrimonial Causes Act [Cap 192] s 2(1)(a)).In Fiji, if a party was incapable of consummating, the marriage used to be rendered voidabl e (Matrimonial Causes Act [Cap 51] s 9(1) (a)) 70 whilst wilful and persistent refusal to consummate was a ground for divorce (Matrimonial Causes Act [Cap 51] s 14(c)). The new Family Law Act abolishes this ground for divorce. Inability of failure to consummate may however lead to the irretrievable breakdown of the marriage. In Tuvalu the term â€Å"voidable† is not used but wilful refusal to consummate provides an entitlement to divorce (Matrimonial Proceedings Act [Cap 21] s 8).LW310 Family law 4. 14 The Marshall Islands legislation provides that:- ‘A decree annulling a marriage may be rendered on any ground existing at the time of the marriage which makes the marriage illegal and void or voidable. A court may, however, refuse to annul a marriage which has been ratified and confirmed by voluntary cohabitation after the obstacle to the validity of the marriage has ceased, unless the public interest requires that the marriage be annulled. (26 MIRC 1 s 12)?In Kiribati it is a ground for divorce if the respondent has either wilfully refused or is incapable of consummating the marriage (Native Divorce Act [Cap 60] s 4(d)) whilst in Tonga the section is much wider and provides that if:- †¦ the respondent at the time of the marriage is and continues to be incapable of consummating the marriage by reason either of some structural defect in the organs of generation which is incurable and renders complete intercourse impracticable or of some incurable mental or moral disability resulting in an invincible repugnance to sexual intercourse with the petitioner. Divorce Act [Cap 29] s3 (1) (e)) The petitioner has grounds for the marriage to be dissolved. In the region, only Tokelau does not provide for failure to consummate as either a ground for divorce or as possibly rendering a marriage voidable. IV. Cruelty Whilst cruelty is not mentioned specifically in the legislation of Cook Islands, Nauru, Niue and Tonga it is a ground for divorce elsewhere in the region in Kiribati Marshall Islands and Samoa. In Vanuatu, such cruelty must be â€Å"persistent†.A clear consideration of what may amount to cruelty was considered in the case of Kong v Kong [1999] VUSC 41. See also the approach taken in the Marshall Islands where; „the guilt of either party toward the other of such cruel treatment, neglect or personal indignities, whether or not amounting to physical cruelty, as to render the life of the other burdensome and intolerable and their further living together unsupportable? (26 MIRC 1 s 15(b)81) †¦is a ground for divorce.The scope of the cruelty is extended by the Regulations in Tokelau which specify that the cruelty can be directed to the applicant or â€Å"a child of the applicant† (Tokelau Divorce Regulations 1987 Reg. 3). The applicable provisions in Cook Islands, Niue and Samoa require that the respondent be not only habitually cruel but a â€Å"habitual drunkard† as well ((NZ) Matrimonial Proceedin gs Act, 1963 s 21 (e); (NZ) Niue Act 1966 s 534 (3)(d); Divorce and Matrimonial Causes Ordinance 1961 s 7(1)(c)83). LW310 Family law 4. 5 In the Solomon Islands case of Elaine Bui v Anthony Makasi [1993] SBHC 3, the applicant succeeded in obtaining a divorce on the ground of cruelty. Justice Palmer held that it was not necessary to find physical violence and considered four specific allegations. Three of the allegations involved assaults and threats against the petitioner whilst the respondent was drunk and the fourth allegation involved an assault on the eldest child of the parties. READ THE CASE NOW V. Criminal ConvictionsIn the Cook Islands, Samoa, and the Solomon Islands and for non i-Kiribati only a respondent husband can be guilty of rape, sodomy or bestiality and sued for divorce by his wife. (Cook Islands Matrimonial Proceedings Act, 1963(NZ) s 21(1)(h);Kiribati Matrimonial Causes Act 1950 (UK) s 1; Samoa Divorce and Matrimonial Causes Ordinance 1961 s 7(1)(k), Solomon Islan ds The Islanders Divorce Act (Cap 48) s 5 (1) and Matrimonial Causes Act 1950 (UK. ) s 1) In Vanuatu, a wife may divorce her husband if he has been â€Å"convicted of rape or an unnatural offence† (Matrimonial Causes Act [Cap 192] s5).Incest, attempted rape or assault with intent to rape a child of the either party provides a ground for divorce in the Cook Islands Matrimonial Proceedings Act 1963 (NZ) s 21(1) (g) and Niue (Niue Act 1966 (NZ) s 543(f)) as does sexual intercourse or attempted sexual intercourse with the child. Husbands in Niue who commit rape or buggery(s 543(g) or either party to a marriage in the Cook Islands, Samoa or Niue who is convicted of murder may also be divorced.Other criminal convictions which provide a ground for divorce are those which result in various periods of imprisonment including for a life sentence, seven years and five years. (E. g. Marshall Islands 26 MIRC 1 s 15(e) stipulates imprisonment for life or for three years or more; see also: S amoa Divorce and Matrimonial Causes Ordinance 1961 s 7(1)(l) and Tonga The Divorce Act, 1927 s 3 (1)(a)). Serious offences against the petitioner are also specifically provided as a ground for divorce in three jurisdictions.In three of these, offences against a child of the parties are included: Cook Islands (Matrimonial Proceedings Act, 1963(NZ) s 21(1) (f); Niue (Niue Act 1966 (NZ) s 534 (3) (e)) and Samoa (Divorce and Matrimonial Causes Ordinance 1961 s 7 (d)) READ s 7(d) Divorce and Matrimonial Causes Ordinance, 1961(Samoa) VI. Drunkenness In the jurisdictions where drunkenness is a ground for divorce, such as Cook Islands (Matrimonial Proceedings Act 1963(NZ) s 21(1) (f)) Samoa (Divorce and Matrimonial Causes Ordinance 1961) s 7(1) (d)) and Niue (Niue Act 1966 (NZ) s 534 (3) (e)) the legislation is not uniform although the CookIslands, Niuean and LW310 Family law 4. 16 Samoan Acts are in very similar terms. As noted above these Acts link drunkenness and cruelty. They also link other behaviour with drunkenness along the lines of traditional gender roles in marriages, as illustrated by the Samoan provision which states; that the respondent has for three years or more been a habitual drunkard and has either habitually left his wife without sufficient means of support or habitually been guilty of cruelty toward her; or, being the petitioner? wife has for a like period been a habitual drunkard and has habitually neglected her domestic duties and rendered herself unfit to discharge them. (Divorce and Matrimonial Causes Ordinance 1961) s 7(1) (c)) In the Cook Islands and Niue, the relevant section is in similar terms with a three year time period for a husband who is a habitual drunkard or drug addict and who either leaves his wife without means of support or who is habitually cruel to her. (Cook Islands Matrimonial Proceedings Act, 1963(NZ) s 21(1) (e); Niue, Niue Act 1966 (NZ) s 534(3) (d)).A wife must be similarly addicted and either habitually neglect her do mestic duties and have been unfit to discharge them or be habitually guilty of cruelty towards the husband. (Cook Islands Matrimonial Proceedings Act, 1963 (NZ) s 21 (e)(i)which prescribes a period of two years following amendment by the Cook Islands Amendment Act1982; Niue Niue Act 1966 (NZ) s 534(3) (d)(i)). In the Marshall Islands the time period is reduced to not less than one year.The applicable section requires â€Å"habitual intemperance in the use of intoxicating liquor or drugs† (26 MIRC 1 s 15(d)). Obviously the time restrictions are used to bar applications for divorce after one or several episodes involving excessive use of alcohol or other drugs. VII. Failure to Maintain In Niue and in Samoa a petitioner wife may only rely on insufficient means of support if the respondent husband is a habitual drunkard or addict (Niue Act 1966 (NZ) s 534(3) (d) (i) and Divorce and Matrimonial Causes Ordinance (1961) s 7(1) (c) (Samoa)).The equivalent provision in Marshall Island s targets the â€Å"wilful neglect by the husband to provide suitable support for his wife when able to do so or when failure to do so is because of his idleness, profligacy or dissipation† (26 MIRC 1 S15 (I)). VIII. Presumed Dead In the Cook Islands it is a ground for divorce if the respondent can be presumed dead on reasonable grounds. (Matrimonial Proceedings Act, 1963 (NZ) s 19) Separate provision is made for this in Samoa where five years absence is required (Divorce and Matrimonial Causes Ordinance (1961) s 8) and in Nauru, Marshall LW310 Family law 4. 7 Islands and Vanuatu the period is seven years (26 MIRC 1 s 29; Matrimonial Causes Act 1973 s 29; Matrimonial Causes Act (Cap 192) s13). The United Kingdom legislation applying in Kiribati and Solomon Islands also makes separate provision for a decree of presumption of death and dissolution of marriage after seven years of absence (Kiribati Matrimonial Causes Act 1950 (UK) s 16; Solomon Islands Matrimonial Causes Act 195 0 (UK. ) s 16). IX. Unsound Mind or InsanityIn the Cook Islands a marriage is rendered voidable if at the time of the marriage either party was a â€Å"mental defective† (Matrimonial Proceedings Act, 1963 (NZ) s 18 (2) (b)). Insanity, provided that it has existed for three or more years may provide grounds for divorce in one country (see Marshall Islands 26 MIRC 1 s15 (f)) but other jurisdictions refer to the â€Å"unsound mind† of the respondent to divorce proceedings. The length of time that a person has been of unsound mind, possibility of recovery and proof of the condition are material.Some jurisdictions require that the respondent be under care and treatment continuously for five years prior to the presentation of the petition for divorce (e. g. Cook Islands Matrimonial Proceedings Act, 1963(NZ) s 21(1)(l); Kiribati Native Divorce Ordinance [Cap 60] s 4(e);Kiribati Matrimonial Causes Act 1950 (UK) s 1(d); Niue, Niue Act 1966 (NZ) s 534(3)(k); Samoa Divorce and Ma trimonial Causes Ordinance (1961) s 7(f), (g); Solomon Islands The Islanders Divorce Act [Cap 48] s 5 (1)(d) and Matrimonial Causes Act 1950 (UK. s 1 (d); Tonga The Divorce Act, 1927 s 3 (1)(d); Vanuatu Matrimonial Causes Act [Cap 192] s 5 (a)(iv)). Samoa extends its provision to cover the possibility of a confinement in another country (Divorce and Matrimonial Causes Ordinance (1961) s 7(1) (g)). The Cook Islands, Niue and Samoa also cover the possibilities of respondents being of unsound mind intermittently and continuously for a number of years (Matrimonial Proceedings Act, 1963 (NZ) s 21(1) (j), (k); Niue Act 1966 (NZ) s 534(i) (j); Divorce and Matrimonial Causes Ordinance (1961) s7 (f) & (g)).Respondents must be either â€Å"unlikely to recover† (Cook Islands, Niue, Samoa, Tuvalu) or â€Å"incurably of unsound mind† (Kiribati, Solomon Islands, Tonga and Vanuatu). Reference may be made to applicable Mental Health legislation (Kiribati, Niue, Samoa, Solomon Islands and Tuvalu). There is no reference to insanity or unsound minds in Nauru or Tokelau. READ s 7 Divorce and Matrimonial Causes Ordinance, 1961(Samoa) X. Marital Breakdown – Living Apart The legislation in Marshall Islands, Nauru and Tonga provides a â€Å"catch all† provision in identical terms dealing with the behaviour of the respondent generally.The provisions require that the petitioner â€Å"cannot reasonably be LW310 Family law 4. 18 expected to live with the respondent† because of that behaviour (Marshall Islands 26 MIRC 1 s 9(1) (a); Nauru Matrimonial Causes Act 1973 s 9(1) (a) (i); Tonga The Divorce Act, 1927 s 3 (1) (g)). The parties are treated as living apart in Nauru unless they are living with each other in the same household although they may live together for a period or periods not exceeding six months, in an attempt to reconcile, without prejudice.In wider terms, the Tuvalu Act allows parties to divorce on proof that the marriage has broken down where â€Å"in the circumstances it would be unreasonable to expect one party to continue in the marriage relationship with the other†. READ s 9(2) Matrimonial Proceedings Act, (Cap21)(Tuvalu) When a party asks for a divorce on the ground that petitioner and spouse are living apart, is this just another way of claiming that petitioner has been deserted or is this a different ground? Some answer to that question might be provided in the case of Ng Lam v Ng Lam from Samoa.READ the Ng Lam case now XI. Incompatible Temperaments Kiribati is the only jurisdiction to allow divorce on the basis that the temperaments of the parties are incompatible (Native Divorce Ordinance [Cap 60] s 4(j). This is a significant departure from other jurisdictions and is clearly a no fault ground for divorce. The closest comparison is the provision in Tuvalu relating to â€Å"circumstances† as described in the preceding paragraph. However in Fiji, incompatibility of temperament might be a cause of the irretrievable breakdown of the marriage.XII. Disease Whilst the contraction of disease may render a marriage voidable in most jurisdictions it can be used as a ground for divorce in others. Kiribati prescribes â€Å"venereal disease† as a ground for divorce if certified as such by â€Å"a medical officer†(Native Divorce Ordinance [Cap 60] s 4(g)) whereas Tonga specifies affliction with â€Å"an incurable disease capable of being transferred to the petitioner by contagion of infection† (The Divorce Act [Cap 29] s 3 (1) (d)).The Marshall Islands prescribes leprosy as a ground for divorce (26 MIRC 1 s 15(g)) XIII. Other Grounds The Marshall Islands lists â€Å"neglect† or â€Å"personal indignities† as grounds for divorce if this renders the life of the other party â€Å"burdensome and intolerable† and the married life â€Å"unsupportable† (26 MIRC 1 s 15(b)). Kiribati has the additional grounds of epilepsy (Native Divorce Ordinan ce [Cap 60] s 4(f)); duress or mistake (s 4(h)) and parties within prohibited degrees of LW310 Family law 4. 9 consanguinity or affinity (s 4(i)) as grounds for divorce. Other jurisdictions categorise such issues as rendering a marriage void or voidable (e. g. Cook Islands Matrimonial Proceedings Act, 1963(NZ) s 7(1) (a) (ii); Niue Niue Act 1966(NZ) s 515). Similarly, the Tongan Act states that it is a ground for divorce if a respondent has a former spouse still living (s 3 (1)(b)), whereas this situation renders a marriage void in Cook Islands, Nauru, Solomon Islands, Samoa and Fiji.The Cook Islands and Niue provide that a husband can file for a divorce if without his consent his wife has been â€Å"artificially inseminated with the semen of some man† other than himself (Matrimonial Proceedings Act, 1963 (NZ) s 21(1)(b) and Niue Act 1966 (NZ) s 534(3)(b)). A marriage is rendered voidable in Cook Islands (Matrimonial Proceedings Act, 1963 (NZ) s 18 (2) (d) and IN Vanuatu (Mat rimonial Causes Act (Cap 192) s 2 (1) (d)) if a wife is pregnant at the time of her marriage by some person other than the petitioner.The Cook Islands takes this situation further by providing for dissolution where a woman other than the petitioner wife is pregnant by the respondent (Matrimonial Proceedings Act, 1963 (NZ) s 18 (2) (d)) 2. Cus tomar y Di vor c e The divorce laws of the region are governed by written legislation – much of it introduced under colonial administration and now therefore, quite out of date. Where marriages may be entered into according to custom then customary divorce applies. This occurs in Vanuatu and Solomon Islands. Customary divorce also has some problems.Consider the two cases below. Both are from Melanesia. In all other respects, the two cases are very different. As you read To? ofilu v Oimae, a case from Solomon Islands, and the Wagi Non case from Papua New Guinea, consider what differences, if any, there are between the customary law of div orce and the statutory law of divorce. Consider also the attitudes of the two judges towards custom. READ To? ofilu v Oimai now And, when you have finished that case READ Application of Wagi Non 3. RECOGNITION OF FOREIGN DIVORCE DECREESAs Pacific people acquire greater mobility and come into contact with people of other nationalities and who are domicile in other countries it is not unusual that marriages and divorces occur outside the region or in a different jurisdiction. It is therefore important to know what recognition is given by domestic law to these decrees. LW310 Family law 4. 20 In Nauru, the Recognition of Foreign Divorces, Legal Separations and Nullity of Marriages Act 1973 provides guidelines for judicial recognition of foreign orders or decrees. The following sections give the grounds for recognition and the exceptions from recognition respectively:- . 4 (1) The validity of a foreign divorce, legal separation, annulment of marriage or declaration of invalidity of marri age shall be recognised if, at the date of the institution of the proceedings in the country in which it was obtained – (a) either spouse was habitually resident in that country, (b) either spouse was a national of that country; or (c) the proceedings by means of which it was obtained were held in the exercise in that country of a jurisdiction similar to any jurisdiction conferred in the Family Court in respect of proceedings in Nauru by section 44 of the Matrimonial Causes Act 1973. 2) In relation to a country the law of which uses the concept of domicile as a ground of jurisdiction in matters of divorce, legal separation or nullity of marriage, paragraph (a) of the preceding section shall have the effect as if the reference to habitual residence included a reference to domicile within the meaning of that law. (3) In relation to a country comprising territories in which different systems of law are in force in matters of divorce or legal separation, the preceding provisions of this section, except those relating to nationality, shall have effect as if each territory were a separate country†. s. 9 (1) Recognition by virtue of this Act of the validity of a divorce, legal separation, annulment of marriage or declaration of invalidity of marriage obtained outside Nauru may be refused if, and only if – (a) it was obtained by one spouse – (i) without such steps having been taken for giving notice of the proceedings to the other spouse as, having regard to the nature of the proceedings and all the circumstances, should reasonably have been taken, or ii) without the other spouse having been given, for any reason other than lack of notice, such opportunity to take part in the proceedings as, having regard to the matters aforesaid, he should reasonably have been given: or (b) its recognition would manifestly be contrary to public policy. (2) Nothing in this Act shall be construed as requiring the recognition of any findings of fault made in a ny proceedings for divorce, legal separation or annulment or of any maintenance, custody or other ancillary order made in any such proceedings. LW310 Family law 4. 21 READ the following case Meleisea v Meleisea [1994] WSSC 24 Where legislation does not deal with the recognition of foreign decree, courts must have recourse to the common law. The case example above shows how this may occur in practice. It also highlights possible evidentiary problems when dealing with overseas decrees. 4. Divorce: Marital Agreements, Collaborative Law, Mediation and Family Arbitration Litigation has for a long time been the traditional battlefield for disputing parties within the Family Law.The financial and emotional cost of litigation in the Family Courts is an issue that has often prompted debate over the years. When parties engage themselves in long, drawn out disputes, the strain is not just felt financially, the children will often be victims, courts are clogged with an overflow of cases and the public will end up bearing the burden of resources spent. The time has come for courts to begin utilising different forms of resolving disputes within the courts and one such mechanism is arbitration or alternative dispute resolution (ADR).Dispute resolution is not a new concept to the South Pacific as most societies are familiar with one form or another. ‘Most Pacific societies are familiar with the ideas of â€Å"alternative dispute resolution† without necessarily being familiar with the term. As Vanuatu Chief Justice Lunabek informed a conference on conflict resolution held in Vila in 2000: â€Å"ADR is not a new concept to Pacific Island jurisdictions and, in particular, to Vanuatu. It is, in fact, consistent with traditional methods of dispute resolution that predated the introduction of the formalised system of justice. The resolution of conflict is described as being â€Å"deeply embedded in the culture† in many societies, so that its structures remained unobtrusive.? (Graham Hassal, „Alternative Dispute Resolution in Pacific Island Countries? [2005] 9 (2) Journal of South Pacific Law) In jurisdictions that utilise ADR in the Family Court, there are different processes currently available and these include: i. Counseling This can be likened to a sort of therapeutic process that is aimed at examining the underlying conflict between parties and with the goal of assisting with reconciliation.Parties are encouraged to sort out their differences rather than opting to go to court. In Fiji, one of the key strategies in the Family Law Act to provide support to troubled families is to make available within the Family Court an on-site counseling service. There is statutory requirement under s. 11 of the LW310 Family law 4. 22 Act for the Director of Counseling to „advertise the existence and availability of the counseling and welfare facilities of the respective Family Division? and as far as practicable, to make those facilities available to those seeking such services.The Act provides for three different types of counseling and these are marriage reconciliation, family and child counseling and financial and property conciliation. (See also the Family Protection Act, Vanuatu) Child counseling is an important component because the focus is on the parents coming to an agreement about issues pertaining to the child (ren) and this is done with the belief that the best judges of the children’s best interest are the parents and not the court. Section 50 and 51 of the Family Law Act, Fiji make provisions for child counseling.This is where a parenting plan may be drawn up by the parents. Some issues that the plan will address is where and with whom the child is to reside (focus will be on the effect of relocating a child from a familiar environment), the issue of contact between the child and the non-custodial parent and other persons, the maintenance of a child and any other aspect of parental responsibili ty towards the child. ii. Negotiation (including round table conferences and collaborative law) This seems to be the most common form of dispute resolution in family law.The simplest example of negotiation is where separated parties have discussions with each other to determine if they can resolve some or all of their issues. This is very similar to counselling where parties may be focused on what type of parenting arrangement they will agree to. Parties may choose to conduct negotiations on their own or if this proves too difficult then they may engage the services of their lawyers who will negotiate on their behalf. The latter form is now known as round table conference. A round table conference is one where parties and lawyers meet together, generally at one of the lawyers offices, to undertake settlement discussions. One or both lawyers will initiate the meeting. The conference can be used to resolve any type of legal issues, such as those about parenting and property and financ es. Lawyers need to come to the meeting prepared with all relevant information, such as valuation of properties and superannuation entitlements, where there is property dispute. If a dispute is complex, a series of round table conferences may be needed.? Alexander Harland et al, Family Law Principles (1st ed. 2011) A more complex form of negotiation is known as collaborative law which aims to resolve matters without recourse to litigation. Parties who choose to participate in this type of negotiation must sign an agreement that commits each of them to the process and this agreement includes an undertaking that parties will not resort to litigation. If one party wishes to opt for litigation then the disputing parties’ lawyers must be changed as they had originally signed the agreement on litigation.This is one drawback of this option. ‘Collaborative law may be appropriate where:  ¦ Parties in low conflict are motivated to work together with the assistance of their lawy ers to resolve their dispute, without going to court;  ¦ Parties are committed to negotiating a settlement outcome;  ¦ Parties may have substantial assets, and then can involve their accountant and financial advisors in the negotiation process.? (Alexander Harland et al, Family Law Principles (1st ed. 2011) This form of negotiation first began in the United States and Canada and is today used in Australia. ii. Mediation Mediation is a process where a third party enters the dispute as a sort of referee and to facilitate the discussion between disputing parties. This third party may be someone from the community, the family court, a counsellor, and even lawyers. The Family Court of Fiji operates according to simple, appropriate and effective procedures, offers counseling and mediation support services. „Mediation may be appropriate where:  ¦ Parties are able to negotiate with assistance and want to work towards settlements; Both parties are able to negotiate during the pro cess and are not prevented from doing so by an overwhelming power imbalance, due to family violence, mental health problems, cultural factors or other issues (or the process can be structured in an appropriate way; for example, shuttle mediation in separate rooms and each party has a lawyer representative during the mediation).? (Alexander Harland et al, Family Law Principles (1st ed. 2011) iv. Conciliation This process is not one aimed at getting the parties back together.Rather it is designed to allow for the disputing parties to settle issues regarding the settlement of matrimonial property. ‘The conciliator will be a qualified lawyer who will receive training in conciliation and alternative dispute resolution skills. They will discuss who will live in the matrimonial home or whether it should be sold; whether payments are to made to the Bank for loans; how much maintenance is to be paid for the children or the other spouse if relevant; how income once going into one family will be shared between two homes; their various financial commitments to the Bank or other debtors and any other financial matters.? Imrana Jalal (2009) in Narawa-Daurewa U, The Family Law Act of Fiji, 2003: A Brief Review of Provisions in the Act; The Impact on the Family (with Emphasis on Women? s Access to Justice) (LLM thesis, University of the South Pacific, 2010) Again the idea of this type of service in the Family Courts is to ensure that parties are the best judges and should try to resolve the issues themselves rather than litigating. v. Arbitration Arbitration is again another means of trying to resolve disputes by means of a third party involvement.The difference between arbitration and mediation is that with the latter you always have the choice of backing out or not accepting the options being offered by the other party (spouse). In arbitration, although the arbitrator cannot grant a divorce, they do have power over how property distribution and custody and access issu es are resolved. An upside to arbitration is that parties are able to keep matters out of court and private and it is also more cost effective. The downside is that for jurisdictions that offer arbitration processes in family law the order made by the arbitrator is not binding until registered in court.See for example, the Family Law Act of Australia. Conclusion Arbitration should be advanced as a desirable alternative to litigation. A revision of the family legislation in countries of the South Pacific is necessary at this time in light of the ever-increasing use of arbitration and the developments of the law in this area. Alternative dispute resolution is being used in other areas of law as a means of resolving disputes without litigating and so it begs the question, why is the family law being left behind? . Conc lus ion There are various models of divorce law evident in the USP region which can provide comparisons for reformers. Tuvalu, Kiribati, Nauru and Tuvalu have partial no fault systems and the remainder are largely fault based. Some, however, have retained the concept of matrimonial fault whilst allowing divorce after a relatively short period of separation. Those laws which focus on â€Å"fault† do so because this was the approach of colonial law prior to independence.This has also led, in two countries, to the application of different matrimonial laws to people in the same jurisdiction on the basis of race rather than relying on the domicile or residence of the petitioners. The legislation also reflects a time and culture when the roles of men and women were largely unquestioned and family life was designed for the procreation of children, the passing of inheritance to ones offspring and the restriction of sexual activity to the parties of the marriage exclusively. This is reflected most dramatically in some of the ‘failure to maintain’ grounds.In Samoa, alcoholic husbands must be sure to financially support their wives or face the possibility of divorce while alcoholic wives must determine the nature of their domestic duties and carry them out without neglect. Niue and the Cook Islands alert husbands to the possibility of wives being artificially inseminated with semen which is not theirs, whilst husbands in the Cook Islands and Vanuatu may opt out of a marriage if their wives, at the time of marriage and without their knowledge, were pregnant by a person other than themselves. Wives in the Cook Islands also have redress if their husband has fathered a