How to write college paper
Wednesday, September 2, 2020
Developing Language Skills Assignment Example | Topics and Well Written Essays - 1250 words
Creating Language Skills - Assignment Example In any case, no one but few can be utilized for a particular level or explicit motivation behind educating. Before choosing a necessary material it is imperative to profile Students instructional requirements and institutional objectives. To settle on choice that what and how to show a specific gathering of students, the instructors ought to have some fundamental information. Instructor ought to be legitimately educated about the student populace, understudy needs, and institutional objectives. A deliberate and continuous needs evaluation ought to clearly be an essential wellspring of information for both course structure and materials choice, so instructors can pick materials that best suit objectives and destinations. Before assessing course readings, educators ought to in this manner study their understudies' experiences and the necessities of their projects and organizations, maybe by checking on the discoveries of an ongoing need evaluation. In the wake of getting the fundamental data about the aptitudes of student it has gotten simpler to choose reasonable assets for students. As depicted over a tremendous scope of distributed material is accessible that can be utilized for creating abilities of students. Following four exceptionally well known books were chosen after intensive examination and examinations. An exercise plan is an exhaustive and foreordained timetable of each movement of instructor in homeroom for accomplishing ideal outcomes. An exercise plan can be of numerous structures and types. It generally relies upon time range, style of teacher and sort of subject to be instructed. Be that as it may, the fundamental and principle target of an exercise plan is to give instructor a pre-arranged line of activity for giving materials and cooperating students. The exercise plan ought not be only an activity plan yet it should give a valuable connection between goals of educational program and material to be instructed. According to directions a nitty gritty two-hour exercise plan is introduced here for ESOL Curriculum Level I. First section of basic and appealing novel of Charlotte Bront Jane Eyre
Saturday, August 22, 2020
La bodas de Sangre - Blood weeding (federico Lorca) & Blood weeding Essay
La bodas de Sangre - Blood weeding (federico Lorca) and Blood weeding Film (Carlos Saura) - Essay Example Concerning Leonardo as the dim stream shows respect and life-demise as the association is genuinely clear when the Bride alludes to the deadly power of the dull waterway rather than the ââ¬Å"little bit of water. The ââ¬Å"little bit of water represents the Bridegroom from which she sought after youngsters. Imagery that in the film, the orange blooms that the lady of the hour wore were phony and waxy which represented the phony society wherein she lived. In the film the lady of the hour wears the phony orange blooms to her wedding as it represents her adjustment to the general public in right around a deriding way.â This goes along with the dark dress she wears for the wedding, as though representing her hopelessness and misery at proceeding with the weddingâ when she truly adores Leonardo. The verses drive of the play finishes in the film, where the topics of respect and enthusiasm are caught up in the topic of death that which incomprehensibly is life. The play of twofold viewpoint of death that are recommended in the double sign as death is supposed to be an Old Woman requesting for a hull of bread. In another picture Death is supposed to be white confronted and the moon aching forever and looking for in the demise of the men is represented by a heart, the peak of the fire, and re d blood for his cheeks. The service of setting up the Bride in the congregation and the merriments going before the section of the Bride and Groom in to the marriage chamber. The two verses utilize the natural image of a blossom, branch, and stream and both make obvious another string of image that is to get noticeable as the topics of pride and enthusiasm push toward their definitive goals in the topic of death. The image of fire is improved as it is connected with respect too enthusiasm and passing. The pony in the Lullaby is to be related to Leonardoââ¬â¢s pony and his injuries with the destiny of Leonardo is shown by the activity going with the tune.
Friday, August 21, 2020
Nature Based Therapy Free Essays
Presentation Nature based treatment is certainly not another idea, our well â⬠being and relationship with nature is a piece of the endless human mission of who were are and exactly where is our place in this tremendous condition which encompasses us. So as to all the more likely handle the subject of nature based treatment or ecotherapy, examines counseled were those relating to our association with nature and our prosperity. Exactly how does nature connectedness influence our encountering of a decent life is the subject of the main paper investigated, by Howell, J. We will compose a custom exposition test on Nature Based Therapy or then again any comparative theme just for you Request Now A. , Dopko, R. L. , Passmore, H. , Buro, K. (2011). The second paper by Jordan Marshall (2010) depicts a the progressions to the conventional treatment outline in a the unsure condition of the outside. In taking treatment outside, we work with nature as one of the factors in the helpful relationship. The integrative, regularly experiential methodology of nature-based treatment or ecotherapy, is increasing quick ground in the field of guiding and psychotherapy. My last research paper targets looking further into this developing field and how it can help those experiencing uneasiness, burnout and discouragement. Article Review A Howell, J. A. , Dopko,R. L. Passmore, H. , Buro, K. (2011). Nature connectedness: Associations with prosperity and care. Character and Individual Differences, 51 (2), 166-171. Howell, Dopko, Passmore and Buro (2011) dive profoundly into the subject of our connectedness with nature and how it tends to be estimated as an impression of our psychological prosperity. The creators, all from the Grant MacEwen Universit y in Edmonton Alberta led two experimental investigations proving this relationship with information exhibiting that association with nature might be increasingly advantageous to our enthusiastic and social prosperity that recently figured it out. Drawing from the Biophilia speculation contended by Harvard developmental scholar E. O Wilson in 1984, that people have an intuitive, passionate and hereditary should be in contact with nature, Howell et al. , subsequently estimate that ââ¬Å"higher levels of nature connectedness would be related with more significant levels of prosperity and with more prominent care. â⬠Many examinations have been led regarding the matter with different outcomes. Howell et al. , depict an investigation led by Mayer and Franz in 2004 which indicated a ââ¬Å"significant relationship between's quality nature connectedness and life satisfactionâ⬠(p. 66). They are mindful so as to characterize the word characteristic and give an apparently through survey of the subjective factors in current writing, examining the adjustments in meaning of prosperity by different scholars (Nisbert, Zelenski and Murphy, 2011). The group from Alberta expands upon ebb and flow investigate by examining further in to the topic of the ââ¬Å"whether attribute nature connectedness was related with feeling admirably â⬠¦ and with working great â⬠¦ just as the relations among nature connectedness and a second list of positive psychological well-being, mindfulnessâ⬠(p. 67). Howell et al. , survey a lot of research, characterize phrasing and reveal new gaps in the speculations, they at that point proceed to represent the theories: ââ¬Å"are more significant levels of nature connectedness related both with more elevated levels of prosperity and with more noteworthy care? â⬠Methodology Howell et al. , directed two examinations utilizing quantitative techniques. In the primary investigation, information was gathered from 452 college understudies, principally female, with ââ¬Å"81. 1% recognizing Canada as their nation of birthâ⬠(p. 167). Utilizing an assortment of polls including Mayer and Franz (2004) 14-thing Connectedness to Nature Scale, Keyesââ¬â¢ (2005) 40-thing, proportion of prosperity and Brown ; Ryanââ¬â¢s (2003) Mindful Attention Awareness Scale (MASS). So as to guarantee objectivity of results, Howell et al. , adjusted these scales by utilizing Paulhusââ¬â¢s (1994) Balanced Inventory of Desirable Responding which serves to sift through ââ¬Å"unintentionally swelled self-portrayals and impression managementâ⬠(p 168). In the second examination 275 understudies took an interest, all understudies of comparative age and segment as thefirst study. Howell et al. , utilized a couple of similar polls including the Allo-Inclusive Identity Scale (Leary, Tipsord ; Tate, 2008) just as the Philadelphia Mindfulness Scale (PMS) (Cardaciotto, Herbert, Forman, Moitra, Farrow, 2008). While trying to give consistency and legitimacy to the outcomes, Howell et al. , give concise definitions and guides to a portion of the inquiries on these scales all together that the peruser better comprehend the unobtrusive contrasts in the expressive measurements of the factors. Results Variables, for example, connectedness to nature, nature relatedness, allo comprehensive character, passionate prosperity, mental prosperity, social prosperity, MAAS, PMS mindfulness and PMS acknowledgment indicated relationships between's tendency connectedness and prosperity. Unmistakable insights were estimated and afterward connected among factors utilizing corroborative factor examination (CFA). Howell et al. , likewise furnished models with estimated relationships between's inclination connectedness, well - being and care. In the main investigation ââ¬Å"associations between nature connectedness and prosperity and between prosperity and care were noteworthy; be that as it may, the relationship between nature connectedness and care was notâ⬠(p. 168). In the second examination , relationships were huge as for mental and social and enthusiastic prosperity and with the additional grades added to the soup, nature connectedness was seen as altogether corresponded to care. Conversation Howell et al. are happy with their steady discoveries and that most consequences of their two investigations bolster their speculation and recommend that â⬠nature connectedness is related with the degree to which individuals are thriving in their private, individual livesâ⬠(p. 170). Howell et al. do concede that a portion of the discoveries were conflicting with their theory and that future research could look at ââ¬Å"moderators and middle people of the connection between nature connectedness and mental hea lthâ⬠(p. 170). They go onto talk about future research prospects and difficulties, including how nature could be fused into different exercises to deliver most extreme remedial outcomes. Howell et al. , delivered persuading investigation into the connection between connectedness to nature and prosperity. They considered different sizes of effect so as to gather their outcomes and painstakingly depicted their disparities and their effect on the conclusive outcomes. I feel their destruction is in their example size and segment and suspect outcomes might be distinctive relying upon age and culture. Maybe new appraising scales would should be created so as to mirror these distinctions. Basically, nature can profit all of us and paying little heed to the result being available inside a common habitat will assist you with figuring out how to encounter the second and maybe even a reestablished imperativeness throughout everyday life. Article Review B Jordan, M. , ; Marshall, H. , (2010). Taking directing and psychotherapy outside: Destruction or improvement of the helpful casing? European Journal of Psychotherapy and Counseling, 12 (4), 345-359 We as a whole realize that nature can assist us with feeling much improved, however exactly how might we take a conventional remedial edge outside? What might be the difficulties and what is the capability of this up and coming field of ecotherapy? Ecotherapy speaks to ââ¬Å"a new type of psychotherapy that recognizes the imperative job of nature and addresses the human instinct relationshipâ⬠(p. 354) Martin Jordan and Hayley Marshall utilize social treatment ideas so as to research commonality and asymmetry and how they might be experienced distinctively in nature. Both Jordan ;Marshall are rehearsing enlisted psychotherapists and by utilizing their own encounters, they investigate both the victories and difficulties to the customary structure of a remedial meeting. Jordan ; Marshall address numerous crucial inquiries including how privacy would be tended to in open settings and how timing or the restorative meeting is influenced by working on guiding and psychotherapy outside. They accept that the difficulties to the customary system could be sifted through among customer and advisor and in truth become some portion of the procedure . An adaptable agreement could be drawn up, one open to change. Jordan ; Marshall are mindful so as to give a few meanings of a restorative edge, from eh uber-preservationist ââ¬Å"Psychotherapy ought to be completed in a soundproof counseling room, in a private office in an expert buildingâ⬠(Langs 1982), to ââ¬Å"being seen as an offense or a double relationship for the therapistâ⬠(Zur 2001). However, there are other people who accept that the remedial limit ought to be a powerful procedure (Hermansson, 1997) or that the adaptability in the edge is an open door for ââ¬Å"deepening the helpful work and relationshipâ⬠(Bridges, 1999). Jordan ; Marshall appear to consider every contingency with their own synopsis of a restorative boundaries,â⬠Working outside can illuminate these generally progressively fixed thoughts concerning limits and welcome an inexorably adaptable point of view on issues concerning force and commonality inside the remedial relationshipâ⬠(p. 347). They inspect the adjustments in customer specialist connections and how commonality must not be compared with balance as far as the remedial relationship. Jordan ; Marshall are not recommending a formula for treatment outside nor are they saying treatment is better outside. Their objective with this paper is to introduce their experiential discoveries and perceptions in regards to the difficulties different types of open air treatment confer on the conventional
Wednesday, June 3, 2020
Claims of outstanding balance - Free Essay Example
We have been asked to advise Xana on the likelihood of her being able to bring a successful claim against Yvette under EC law to recover the outstanding balance of her account; namely, that proportion of the total fees payable required, under the Free Movement of Services Act 2008, as a contribution towards the quality audit which Xana is required to undergo in accordance with the provisions of that same Act. Central to this problem question is the Law of the European Union pertaining to the freedom to provide and receive services and also the freedom of establishment In order to provide a reasoned argument in response to this question it will be necessary to examine the provisions of Council Directive 2006/123/EC, which the Free Movement of Services Act 2008 purports to implement; Articles 43 to 55 of the Treaty of the European Union (1992), which provide (inter alia) the core governing principles on which restrictions to aforementioned freedoms are permissible und er EC Law; and, the case law of the European Court of Justice, the decisions from which provide insight into how these principles are likely to be interpreted and applied, in order to determine whether or not: . The tutorial services supplied to Yvette by Xana, on a distance-learning basis, are likely to be considered à ¢Ã¢â ¬ÃÅ"servicesà ¢Ã¢â ¬Ã¢â ¢ for the purposes of Articles 43 to 55 of the Treaty of the European Union and Council Directive 2006/123/EC; The à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ restriction imposed on Xana by the Free Movement of Services Act 2008 is permissible under European law; and, The à ¢Ã¢â ¬ÃÅ"contribution requirementà ¢Ã¢â ¬Ã¢â ¢ imposed on Yvette by the Free Movement of Services Act 2008 is valid, taking into account the overriding objectives of Articles 43 to 55 of the Treaty of the European Union and Council Directive 2006/123/EC. In regard to whether or not the tutorial services supplied to Yvette by Xana, on a distance-learning basis, are likely to be considered à ¢Ã¢â ¬ÃÅ"servicesà ¢Ã¢â ¬Ã¢â ¢ for the purposes of Articles 43 to 55 of the Treaty of the European Union and Council Directive 2006/123/EC: For the purpose of the freedom to provide and receive services across the European Union, a à ¢Ã¢â ¬ÃÅ"serviceà ¢Ã¢â ¬Ã¢â ¢ is defined by Article 50 EC, which states: à ¢Ã¢â ¬Ã
âServices shall be considered to be à ¢Ã¢â ¬ÃÅ"servicesà ¢Ã¢â ¬Ã¢â ¢ within the meaning of this Treaty where they are normally provided for remuneration, insofar as they are not governed by the provisions relating to freedom of movement for goods, capital and persons.[1]à ¢Ã¢â ¬Ã While it has been held by the European Court of Justice, in the case of Belgium v. Humbel[2], that the provision of education by the State does not fall within the scope of this definition, even where students are required to pay fees towards the operational costs of the institutions providing their education; in the present case, because the services provided by Xena are fully commercial and independent from the duties of the United Kingdom to provide subsidized education to its citizens, it is highly likely that the services in question would be deemed to fall within the scope of Article 50 EC. For the purposes of Council Directive 2006/123/EC, a à ¢Ã¢â ¬ÃÅ"serviceà ¢Ã¢â ¬Ã¢â ¢ is defined by Article 4(1) of the Directive as being, à ¢Ã¢â ¬Ã
âany self-employed economic activity[3], normally provided for remuneration, as referred to in Article 50 of the Treaty.[4]à ¢Ã¢â ¬Ã Additionally, a list of activities which are expressly excluded from the scope of the Directive is provided by Article 2(2)(a)-(l) and Article 2(3) of the Directive, which includes such activities as private security services[5] and gambling activities[6]. Because the services provided by Xena to Yvette are o f an economic nature, being provided in return for valuable consideration, and are not of the kind excluded by Articles 2(2) and 2(3) of the Directive, we can conclude that it is likely that the services in question would be deemed to fall within the scope of Council Directive 2006/123/EC. One exception to these rules should be noted briefly: In the case of Grogan[7] it was held that the provision of financial information did not fall within the Treatyà ¢Ã¢â ¬Ã¢â ¢s definition of a service, it rather representing a manifestation of freedom of expression. While it could be argued that Xenaà ¢Ã¢â ¬Ã¢â ¢s primary business activity is supplying her clients with information, the reason that the Grogan decision can be distinguished from this present case is that, in Grogan, the information was being provided for free Xena charges for her information and offers it as part of a structured educational service. We can therefore conclude with some confidence that the service pr ovided to Yvette by Xena qualifies as a à ¢Ã¢â ¬ÃÅ"serviceà ¢Ã¢â ¬Ã¢â ¢ for the purposes of the European Treaty and also Council Directive 2006/123/EC. Bearing this conclusion in mind, we must now turn to consider whether or not the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ restriction imposed on Xana by the Free Movement of Services Act 2008 is permissible under European law: Of particular relevance to this enquiry is the freedom of establishment as provided by Article 43 EC[8]. This Treaty Article provides, inter alia, that: à ¢Ã¢â ¬Ã
â[R]estrictions on the freedom of establishment of nationals of a Member State in the territory of another Member State shall be prohibited.à ¢Ã¢â ¬Ã Within the context, establishment includes the à ¢Ã¢â ¬Ã
âsetting-up of agencies, branches or subsidiaries by nationals of any Member State established in the territory of any Member State,à ¢Ã¢â ¬Ã and also, à ¢Ã¢â ¬Ã
âthe right to take up and pursue activ ities as self-employed persons and to set up and manage undertakings, in particular companies or firms.[9]à ¢Ã¢â ¬Ã While it is true that the à ¢Ã¢â ¬ÃÅ"audit requirementà ¢Ã¢â ¬Ã¢â ¢ does not prohibit establishment of English language service providers in the United Kingdom, the jurisprudence of the European Court of Justice has interpreted the freedom of establishment widely. In the Gebhard[10] case, the European Court of Justice provided four conditions which must be satisfied in order for a restrictive nation measure to be deemed valid at law: à ¢Ã¢â ¬Ã
âIt follows from the Court s case-law that national measures liable to hinder or make less attractive the exercise of fundamental freedoms guaranteed by the Treaty must fulfil four conditions: they must be applied in a non-discriminatory manner; they must be justified by imperative requirements in the general interest; they must be suitable for securing the attainment of the objective which they pursue; and they must not go beyond what is necessary in order to attain it.[11]à ¢Ã¢â ¬Ã This latter requirement of à ¢Ã¢â ¬ÃÅ"necessityà ¢Ã¢â ¬Ã¢â ¢ was provided in the earlier case of Kraus v Land Baden-Wuerttemberg[12] and is further supported by Council Directive 2006/123/EC: à ¢Ã¢â ¬Ã
â[N]o such authorisation scheme or restriction should discriminate on grounds of nationality. Further, the principles of necessity and proportionality[13] should always be respected.[14]à ¢Ã¢â ¬Ã The questions which therefore fall for determination are as follows: Is the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ requirement imposed by the Free Movement of Services Act 2008 an imperative requirement in the general interest[15]? If so, is the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ requirement a suitable and proportionate way of achieving those objectives? And, If so, does the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ requirement go beyond what is necessary to achieve its legitimate objectives? In regard to (a); the justifications which have been proffered by the government of the United Kingdom for the imposition of the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ requirement are two-fold: First, that it promotes à ¢Ã¢â ¬ÃÅ"the purity of the English languageà ¢Ã¢â ¬Ã¢â ¢; and, second, that it à ¢Ã¢â ¬ÃÅ"protect jobs in the UK further and higher education sectorà ¢Ã¢â ¬Ã¢â ¢. In regard to the latter of these aims, because it is an economic aim, i.e. promoting employment for the benefit of the United Kingdomà ¢Ã¢â ¬Ã¢â ¢s economy, the Courts are unlikely to consider this in the à ¢Ã¢â ¬ÃÅ"general interestà ¢Ã¢â ¬Ã¢â ¢ or a à ¢Ã¢â ¬ÃÅ"legitimate public interestà ¢Ã¢â ¬Ã¢â ¢[16]. This conclusion is further supported by the decision in the case of Finalarte Sociedade de ConstruÃÆ'à §ÃÆ'à £o Civil V Urlaubs und Lohnausgleichskasse der Bauwirtschaft[17]. In regard to the former aim: While it is true that one of the legitimate aims suggested by Council Directive 2006/123/EC is the objective of promoting higher quality in education[18], it is difficult to argue that the aim of à ¢Ã¢â ¬ÃÅ"promoting purity of languageà ¢Ã¢â ¬Ã¢â ¢ falls within this legitimate category, especially since the European Courts of Justice generally take an highly restrictive interpretation of à ¢Ã¢â ¬ÃÅ"legitimate aims[19]à ¢Ã¢â ¬Ã¢â ¢. If anything, this profferred justification fits more comfortably inside one of the cutural heads of public policy objectives, such as for the à ¢Ã¢â ¬ÃÅ"promotion of the national language[20]à ¢Ã¢â ¬Ã¢â ¢. However, even if this former aim is considered legitimate and in the general interest, it is not obvious that imposing a costly and rigid[21] à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ is a proportionate way of achieving this objective, nor that it is necessary in order to achieve that objective. For example, Xena might already be in possession of a quality appr oval certification from her home State which would serve the purpose equally well. While this is mere speculation, it reveals one circumstance under which the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ imposed by the Free Movement of Services Act 2008 is a disproportionate and unnecessary requirement in light of the objective of promoting the national language. However, as per the decision in the case of Jean Thieffry v Conseil de lordre des avocats ÃÆ'à la cour de Paris[22], this argument will only defeat the UKà ¢Ã¢â ¬Ã¢â ¢s claim (that the derogation for the freedom of establishment is justified) if it can be shown that there exist equivalent à ¢Ã¢â ¬ÃÅ"qualificationsà ¢Ã¢â ¬Ã¢â ¢ or audit certification processes in other Member States of Europe. If such equivalences exist, then the UKà ¢Ã¢â ¬Ã¢â ¢s claim is more likely to be successful and the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ provision of the 2008 Act will likely be deemed valid. Converse ly, if it is held that equivalences do exist in other Member States, then I would argue that the Courts would not be satisfied that the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ requirement satisfies the test as set out in the Gebhard[23] case. One final point on this enquiry: We have not been provided with details of the enforcement mechanisms which have been adopted under the 2008 Act to compel business compliance; if this Act creates a criminal law offence for failing to undergo the à ¢Ã¢â ¬ÃÅ"quality audità ¢Ã¢â ¬Ã¢â ¢ process, which is quite possible, then the measure must be deemed contrary to the objectives of Council Directive 2006/123/EC which, at Article 1(5) states: à ¢Ã¢â ¬Ã
âMember States may not restrict the freedom to provide services by applying criminal law provisions which specifically regulate or affect access to or exercise of a service activity[24]à ¢Ã¢â ¬Ã We are not in possession of the facts required to make any firm conclusion in this regard. In regard to the final enquiry of this paper; namely, whether or not the à ¢Ã¢â ¬ÃÅ"contribution requirementà ¢Ã¢â ¬Ã¢â ¢ imposed on Yvette by the Free Movement of Services Act 2008 is valid: Of particular relevance to this enquiry is Article 14(1) of Council Directive 2008/123/EC which provides that: à ¢Ã¢â ¬Ã
âMember States shall not make access to a service activity in their territory subject to compliance with discriminatory requirements based directly or indirectly on nationality[25]à ¢Ã¢â ¬Ã Because only residents of the United Kingdom are subjected to this contributory surcharge, there is no doubt that this measure would be deemed discriminatory by the European Court of Justice. This is supported by the decision in the case of Van Binsbergen[26] in which it was held that measures discriminating on grounds of nationality (whether directly or indirectly) must be abolished in accordance with Article 49 of the European Treaties. While it could be argued that because the measure looks to country of residence rather than nationality, per se[27], that it does not discriminate on the basis of nationality. However, this argument is likely to fail as, in practice, this means that more UK nationals are likely to be affected negatively by the measure than non-UK nationals[28]. In conclusion, if Xena brought a claim against Yvette, Yvette would likely be successful in arguing that she should not have to pay the additional audit charge. Even if the Court do accept that the objectives of imposing this charge on Xena are legitimate, proportionate and necessary, the restriction to Yvettes freedom to access educational services has been compromised by a discriminatory measure; namely, the requirement that recipients of English language services in the United Kingdom must pay a surcharge to contribute to the costs of the audit process imposed under the Free Movement of Services Act 2008. References: Barnard, C. and J. Scott, à ¢Ã¢â ¬ÃÅ"The Law of the Single European Marketà ¢Ã¢â ¬Ã¢â ¢, Hart Publishing, Oxford and Portland, Oregon, 2002. Craig, P. and G. De BÃÆ'à ºrca, à ¢Ã¢â ¬ÃÅ"EU Law Text, Cases and Materialsà ¢Ã¢â ¬Ã¢â ¢, Fourth Edition, Oxford University Press, Oxford, 2007 Foster, G. à ¢Ã¢â ¬ÃÅ"Blackstoneà ¢Ã¢â ¬Ã¢â ¢s Statutes EU Treaties Legislationà ¢Ã¢â ¬Ã¢â ¢, Eighteenth Edition, Oxford, Oxford University Press, 2007 Tobler, C., à ¢Ã¢â ¬ÃÅ"Indirect Discrimination: A Case Study Into the Development of the Legal Concept of Indirect Discrimination Under EC Lawà ¢Ã¢â ¬Ã¢â ¢, Antwerpen à ¢Ã¢â ¬Ã¢â¬Å" Oxford, Intersentia, 2005. Footnotes [1] Article 50 of the EC Treaty [2] Belgium v Humbel (Case 263/86) [1988] ECR 5365 [3] Insight into when an activity will be considered à ¢Ã¢â ¬ÃÅ"economicà ¢Ã¢â ¬Ã¢â ¢ is provided by paragraph 17 of the text of the Directive which states: à ¢Ã¢â ¬Ã
âThis Directive covers only services which are performed for an economic consideration. Services of general interest are not covered by the definition in Article 50 of the Treaty and therefore do not fall within the scope of this Directive.à ¢Ã¢â ¬Ã [Council Directive 2006/123/EC, para.17] [4] Article 4(1) of Council Directive 2006/123/EC [5] Article 2(k) of Council Directive 2006/123/EC [6] Article 2(h) of Council Directive 2006/123/EC [7] The Society for the Protection of Unborn Children Ireland Ltd v Stephen Grogan and others (1990) Case C-159/90. [8] The reason that the freedom of establishment provisions of the European Treaty are relevant here rather than the freedom of services provisions is because the services being supplied by Xena are permanent, in that she plans to provide these educational services in the United Kingdom on a regular basis for a significant duration of time. This is very similar to the arrangement pursued by Mr. Gebhard in the Gebhard case: At paragraph 27 in this case it was held: à ¢Ã¢â ¬Ã
âHowever, that situation is to be distinguished from that of Mr Gebhard who, as a national of a Member State, pursues a professional activity on a stable and continuous basis in another Member State where he holds himself out from an established professional base to, amongst others, nationals of that State. Such a national comes under the provisions of the chapter relating to the right of establishment and not those of the chapter relating to services.à ¢Ã¢â ¬Ã Gebhard v Consiglio dellà ¢Ã¢â ¬Ã¢â ¢Ordine degli Avvocati e Procuratori di Milano [1995] Case C-55/94 ECR I-4165 at para. 27. [9] Article 43 EC [10] Gebhard v Consiglio dellà ¢ â⠬â⠢Ordine degli Avvocati e Procuratori di Milano [1995] Case C-55/94 ECR I-4165 [11] Ibid, at para. 37 [12] Dieter Kraus v Land Baden-WÃÆ'à ¼rttemberg (1992) Case C-19/92. [13] In regard to the applicability of the principle of proportionality to assessments of these kind, it was held, in the case of Bond van Adverteerders v Netherlands State [1988] Case 352/85 ECR 2085, that whenever a Member State seeks to rely upon a public policy justification for derogating from a freedom contained in the European Treaty, a proportionality assessment must be conducted when deciding upon the validity of that derogation. [14] Council Directive 2006/123/EC at para. 56. [15] The way that Craig and De Burca (2007) describe this requirement is as follows: à ¢Ã¢â ¬Ã
â[T]he restriction must be adopted in pursuit of a legitimate public interest, which is not incompatible with Community aims.à ¢Ã¢â ¬Ã Craig and De Burca (2007) p827. [16] For example, see the case of SETTG V Ypourgos Ergasias [1991] Case C-350/89 ECR 1-2387, paras. 22-23 [17] Finalarte Sociedade de ConstruÃÆ'à §ÃÆ'à £o Civil V Urlaubs und Lohnausgleichskasse der Bauwirtschaft (1998) Case 71/98. [18] Para. 40 of Council Directive 2006/123/EC: à ¢Ã¢â ¬Ã
â[T]his Directive has been developed by the Court of Justice in its case law in relation to Articles 43 and 49 of the Treaty and may continue to evolve. The notion as recognised in the case law of the Court of Justice covers at least the following grounds: the need to ensure a high level of education.à ¢Ã¢â ¬Ã [19] Barnard and Scott (2002) p9. For an example of a restrictive approach for permitting public policy derogations, see the case of Raymond Kohll v Union des caisses de maladie (1996) Case C-158/96. [20] Fn.12 [21] Rigid in that the audit must be conducted by a à ¢Ã¢â ¬ÃÅ"designated auditorà ¢Ã¢â ¬Ã¢â ¢ appointed from one of the Schools of Education of UK universities and colleges. [22] Jean Thieffry v Conseil de lordre des avocats ÃÆ'à la cour de Paris (1976) Case 71/76 [23] Fn. 10. [24] Article 1(5) of Council Directive 2006/123/EC. [25] Article 14(1) of Council Directive 2006/123/EC. [26] Van Binsbergen (1974) Case 33/74 [27] For example, Yvette is a Polish national being levied with the audit surcharge because she utilized the service while residing in the United Kingdom. [28] Jean Thieffry v Conseil de lordre des avocats ÃÆ'à la cour de Paris (1976) Case 71/76. For a detailed analysis of this argument, see Tobler (2005) p129.
Sunday, May 17, 2020
Americas Roadside Architecture of the 1950s
Googie and Tiki are examples of a Roadside Architecture, a type of structure that evolved as American business and the middle class expanded. Particularly after World War II, travel by car became part of the American culture, and a reactive, playful architecture developed that captured Americas imagination. Googie describes a futuristic, often flashy, Space Age building style in the United States during the 1950s and 1960s. Often used for restaurants, motels, bowling alleys, and assorted roadside businesses, Googie architecture was designed to attract customers. Well-known Googie examples include the 1961 LAX Theme Building at the Los Angeles International Airport and the Space Needle in Seattle, Washington, which was built for the 1962 Worlds Fair. Tiki architecture is a fanciful design that incorporates Polynesian themes. The word tiki refers to large wood and stone sculptures and carvings found in the Polynesian islands. Tiki buildings are often decorated with imitation tiki and other romanticized details borrowed from the South Seas. One example of Tiki architecture is the Royal Hawaiin Estates in Palm Springs, California. Googie Features and Characteristics Reflecting high-tech space-age ideas, the Googie style grew out of the Streamline Moderne, or Art Moderne, the architecture of the 1930s. As in Streamline Moderne architecture, Googie buildings are made with glass and steel. However, Googie buildings are deliberately flashy, often with lights that would blink and point. Typical Googie details include: Flashing lights and neon signsBoomerang and palette shapesStarburst shapesAtom motifsFlying saucer shapesSharp angles and trapezoid shapesZig-zag roof lines Tiki Architecture Has Many of These Features Tikis and carved beamsLava rockImitation bamboo detailsShells and coconuts used as ornamentsReal and imitation palm treesImitation thatch roofsA-frame shapes and extremely steep peaked roofsWaterfallsFlashy signs and other Googie details Why Googie? Googie should not be confused with the Internet search engine Google. Googie has its roots in the mid-century modern architecture of southern California, an area rich with technology companies.à The Malin Residence or Chemosphere House designed by architect John Lautner in 1960 is a Los Angeles residence that bends mid-century modern stylings into Googie. This spaceship-centirc architecture was a reaction to the nuclear arms and space races after World War II. The word Googie comes from Googies, a Los Angeles coffee shop also designed by Lautner. However, Googie ideas can be found on commercial buildings in other parts of the country, most noticeably in the Doo Wop architecture of Wildwood, New Jersey. Other names for Googie include Coffee House ModernDoo WopPopuluxeSpace AgeLeisure Architecture Why Tiki? The word tiki should not be confused with tacky, although some have said that tiki is tacky! When soldiers returned to the United States after World War II, they brought home stories about life in the South Seas. The best-selling books Kon-Tiki by Thor Heyerdahl and Tales of the South Pacific by James A. Michener heightened interest in all things tropical. Hotels and restaurants incorporated Polynesian themes to suggest an aura of romance. Polynesian-themed, or tiki, buildings proliferated in California and then throughout the United States. The Polynesia fad, also known as Polynesian Pop, reached its height in about 1959 when Hawaii became part of the United States. By then, commercial tiki architecture had taken on a variety of flashy Googie details. Also, some mainstream architects were incorporating abstract tiki shapes into the streamlined modernist design. Roadside Architecture After President Eisenhower signed the Federal Highway Act in 1956, the building of the Interstate Highway System encouraged more and more Americans to spend time in their cars, traveling from state to state. The 20th century is filled with examples of roadside eye candy created to attract the mobile American to stop and buy. The Coffee Pot Restaurant from 1927 is an example of mimetic architecture. The Muffler Man seen in the opening credits is an iconic representation of roadside marketing still seen today. Googie and Tiki architecture is well-known in southern California and associated with these architects: Paul Williams, designer of thousands of mid-century modern homes in southern California, may be best known for the LAX Theme Building, shown on this page bathed in Walt Disney colored lightingJohn LautnerDonald Wexler, designer of many mid-century modern homes in Palm Springs, California, is known for designing the Royal Hawaiin Estates in the early 1960sEldon DavisMartin Stern, Jr.Wayne McAllister Sources LAX Theme Building designed by Paul Williams, Los Angeles airport photo by Tom Szczerbowski / Getty Images Sport / Getty Images (cropped)The Royal Hawaiian Estates, Palm Springs, California, photo à © Daniel Chavkin, courtesy Royal Hawaiian EstatesThe Malin Residence or Chemosphere House Designed by John Lautner, 1960, photo by ANDREW HOLBROOKE / Corbis Entertainment / Getty Images
Wednesday, May 6, 2020
Notes On Delinquency Prevention Programs - 4174 Words
Running head: DELINQUENCY PREVENTION PROGRAMS 1 16 17 Delinquency Prevention Programs Alton Johnson American Military University Abstract This research paper will describe a variety of delinquency prevention programs as well as why they are beneficial for today?s society. Pivotal questions regarding the purpose of delinquency programs will be addressed through proven and current research. These programs when coupled with increased parental involvement are proven to be more effective. In my research, studies will also show that mentorship and positive reinforcement are the two most effective factors for rehabilitation after completion of these programs. In today?s society, there is an alarming new trend of more and more adolescents becoming juvenile delinquents, and at an earlier age than previous years. This trend is mostly male dominant but also contain its female offenders. Researchers have studied a number of reasons, topics, and causes for the increasing trend of juvenile delinquency in adolescents and have come to a wide range of conclusions and presumptions based on their research. In these studies researchers looked at a number of topics and questions; what is the definition of juvenile delinquency? What are the current/ recent youth criminology rates and demographics? What are the origins of juvenile delinquency? What are the parental influences on juvenile delinquency? What are the external influences on juvenileShow MoreRelatedThe Theories Believe Biological Or Genetic Risk Factors1554 Words à |à 7 PagesGenes are said to affect a personââ¬â¢s ability to learn some behaviors more readily than others, have ev olved through the natural selection process and predispose people to fluctuating degrees of criminal behavior (Ellis and Walsh, 1997). 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Blakeslee and Keller state that ââ¬Å"The highlyRead MoreDisplacement And Diffusion, Mass Media And Crime Prevention1222 Words à |à 5 Pages3: Displacement and Diffusion, Mass Media and Crime Prevention, General Deterrence Sem Crime Prevention/Control LaBrittani Poole-James October 6, 2017 Grambling State University Assignment 3: Displacement and Diffusion, Mass Media and Crime Prevention, General Deterrence 1. Evaluate the types of Crime Displacement Crime Displacement entails the relocation of a crime an aspect that can result from the actions of Police in their crime prevention efforts. Crime displacement results from various reasonsRead MoreJuvenile Delinquency Is A Crime967 Words à |à 4 PagesJuvenile Delinquency is a crime categorize mainly based on age. Juvenile delinquency the definition under the criminal law it generally refers to behavior which shall be subject to criminal penalties for people age under 18 being implemented. Juvenile delinquency is an increasingly common social problem facing the U.S currently. The problem of juvenile delinquency is also very prominent, and the severity of their crimes have been gaining awareness of the whole society. Poor social environment isRead MoreCause And Effects Of Juvenile Delinquency1458 Words à |à 6 Pagescontinue to assert the probable causes and effects of juvenile delinquency (peaking during teenage phase 15-19) and its increasing provocations into adulthood (declining during the early twenties 40-60%) (National Institute of Justice, 2014). Offenders that were severely delinquent and violent during early youth (below age twelve) posed a higher probability of continuity of offending into the adult phase, in which a Pittsburgh Youth Study notes that 52-57% of juvenile delinquents maintain continuity ofRead MoreHigh Risk Youth : A Public Health Approach By Doctor Dawn Delfin Mcdaniels1368 Words à |à 6 Pagesto identify the risk factors of high-risk youth and by doing so, also identify violence-prevention strategies (McDaniels, 2012). McDaniels analyzed data from the CDCââ¬â¢s 2004 cross-sectional survey ââ¬ËYouth Violence Survey: Linkages Among Different Forms of Violenceââ¬â¢. The data collected from 4,131 youths in grades 7, 9, 11, and 12, in high-risk, urban schools, was used to find an association between delinquency, depression, gang membership, suicidal tendencies, peer victimization, family support, parentalRead More Juvenile Crime Essay example975 Words à |à 4 Pagesrate of juvenile crimes involvin g a firearm is higher on school days than non-school days. Statistics on Juvenile Court Case Flow Of every 1,000 petitioned adjudicated delinquency cases handled in 1997, 177 resulted in formal probation and 94 resulted in residential placement following adjudication. In many formally handled delinquency cases that did not result in juvenile court adjudication, the youth agreed to informal services or sanctions, including out-of-home placement, informal probation, and
Tuesday, May 5, 2020
Hey there, dream girl! free essay sample
ââ¬Å"Oh! Hi Ananya!â⬠this is the general routine daily followed by us to greet each other! Donââ¬â¢t think that I look as if some angel fallen from the sky (what would I not do to look like that!) because Ana calls me ââ¬ËDream girlââ¬â¢, the reason behind this sweet nickname is my tendency to dream off to some far away land in any and every situation!Just yesterday only, sitting in one of the most-irritating teacher`s class and attending one of the most difficult chapter`s lecture I dreamt off to my imaginary land where I got proposed by my crush and not only that he also gifted me a big carton full of dairy milk choc and we even did a typical Bollywood number in the rain and around the tree. The song was coming to an end when I felt a sharp pain in my head and I was jolted back to my S. We will write a custom essay sample on Hey there, dream girl! or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page ST class. Now itââ¬â¢s a different story, that when my lovely S.ST teacher asked what I was doing and pat came my reply that I was dancing and everybody started laughing at me and I was requested to leave the classroom for the 5th time in a row that week. Oh hell!OK, now coming back to the point, a teenage girl has a lot of things on her mind to think about; similar is the case with me. But the problem here is that from the time I started thinking I have been super duper imaginative and unconsciously I had conjured up an imaginary place in my head where I used to fly off whenever I felt that life was getting tough on earth. Believe me I had made that place so beautiful that I found it quite difficult to zap back, and I had even started to lose track of whatever was actually happening in my life! I had started to become quite.. listless. And why not? Everything had started to be quite disappointing in my hellish life. First of all, my marks were going down the trench, my latest crush had crushed all my hopes, I wanted to become the school captain but was made just a house leader and at last, but not the least, nothing was well between my parents and me.One fine day, frustrated of all these, I sat down to figure out what went wrong in the last few months to make my life so very very hellish. Right at that moment, my eyes fell on a piece of paper which was lying on my table for last 2 days but I had not given much importance to it. On it was written ââ¬âââ¬Å"Be the change you want to see in the world.â⬠By M.K. Gandhi. How that paper appeared on my table I really have no idea but it gave me lots of ideas about changing myself for the best.I realised if I wanted to change my marks, then first I should change the way I study. If I wanted to get over my broken heart then first I should change myself from being vulnerable to be strong. I realised I need to change my mentality then I would become better than the cap himself and that idiot would be looking up at me. Yeah! And if I want my parents to listen to me, then first I should listen to them. I really realised that running off to some imaginary place at tough times meant running away from one`s problems and that means running away from the solution. Face the problem and you`ll get the solution. Really, thanks Mr. Gandhi!P.S.: that paper was a reminder about some assignment. Obviously, I remembered about the h.w. while getting the punishment.P.S.: I still visit that place and as you all know what happened yesterday.
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