Proprietary Estoppel Essay

â€Å"In Thorner –v- Major, the House of Lords confirmed that a claimant seeking to establish a proprietary estoppel must prove three things: (1) that the defendant’s assurances or conduct in relation to identified property were sufficiently clear and unambiguous in all the circumstances, (2) to lead the claimant reasonably to rely on those assurances or conduct; (3) by acting significantly to his detriment, so that it would be unconscionable for the defendant to deny him any remedy.† (Per Hayton and Mitchell: ‘Commentary and cases on the law of Trust and Equitable Remedies’, 13th edition, Sweet and Maxwell, page 78) Critically analyse and evaluate this statement in light of recent developments in the law of proprietary estoppel. Despite the lack of a definitive formulation, it is widely accepted that the elements of assurance, reliance and detriment must be present in order to found a claim of proprietary estoppel . The doctrine has however been widely criticised for being too flexible and uncertain. The main cause of this uncertainty is the lack of clarity surrounding the role of unconscionability. It has been stated that unconscionability is â€Å"at the heart of the doctrine,† and yet there is â€Å"little guidance as to what it means, little explanation of why it is at the centre and thus virtually no consideration of the role it might play in providing both a justification for, and a limitation on, successful estoppels† . Commentators have largely agreed that there is a â€Å"need to develop clear parameters for the operation of the doctrine, else it really will be a discretionary panacea for all ills whose application is unpredictable and uncertain. Prior to Thorner v Major [2009] and Cobbe v Yeoman’s Row Management Ltd [2008] it had been 142 years since a case of proprietary estoppel had reached the House of Lords. Therefore it was hoped that these cases would give the judiciary a long awaited opportunity to clarify the doctrine. In Cobbe Lord Walker stated that â€Å"Equitable estoppel†¦is not a sort of joker or wild card to be used whenever the court disapproves of the conduct of a litigant who seems to have the law on his side. Flexible though it is, the doctrine must be formulated and applied in a disciplined and principled way.† The House of Lords appeared determined to address the criticisms and it was hoped that they were about to define and clarify the doctrine, especially the role of unconscionability. Lord Scott, who gave the leading judgement, stated that unconscionability alone is never enough to found a claim of proprietary estoppel. â€Å"To treat a ‘proprietary estoppel equity’ as requiring neither a proprietary claim by the claimant nor an estoppel against the defendant but simply unconscionable behaviour is, in my respectful opinion, a recipe for confusion†. Lord Walker addressed the uncertainty over whether unconscionability is a separate element, by stating that â€Å"unconscionability†¦ does in my opinion play a very important part in the doctrine of equitable estoppel, in unifying and confirming, as it were, the other elements. If the other elements appear to be present but the result does not shock the conscience of the court, the analysis needs to be looked at again† . These emphatic statements confirmed that unconscionability alone is insufficient to give rise to a claim of proprietary estoppel and that the traditional elements must always be present. It is suggested however that these pronouncements did very little in practice to define or clarify the concept. The modern approach to proprietary estoppel which began with Taylor Fashions Ltd v Liverpool Victoria Trustees Co Ltd [1982] adopted a â€Å"broad test of whether in the circumstances the conduct complained of is unconscionable without the necessity of forcing those incumbrances into a Procrustean bed constructed from some unalterable criteria.† Despite this statement the judgement in Taylor Fashions did not rely on unconscionability alone. The court required the three traditional elements to be present, albeit adopting a new claimant centred approach to establishing them. Therefore the statements in Cobbe regarding unconscionability are uncontroversial and do not significantly alter its position within the doctrine. The judgement in Cobbe was regarded as a severe curtailment of the doctrine and was believed to have greatly narrowed the scope of its operation. It was even thought that it had led to the ‘the death of proprietary estoppel’ This was not due to the outcome of the case, but due to the controversial reasoning behind this decision. Lord Scott attempted to rein in the doctrine by focusing on the traditional elements of proprietary estoppel and restricting the doctrine via their operation. He focused on the assurance or representation element, which requires that the claimant must have been led to believe that he has or he will acquire an interest in the defendant’s land. He stated that the required assurance was of a ‘certain interest’ and this meant that the claimant must specify the interest in the property he believed he had or would have. Cobbe dealt with a case of proprietary estoppel in a commercial context. Therefore Mr Cobbe’s â€Å"was not an expectation that he would, if the planning application succeeded, become entitled to â€Å"a certain interest in land† but an expectation â€Å"of further negotiations leading, as he hoped and expected, to a formal contract† . Lord Scott stated that this was not â€Å"the sort of expectation of ‘a certain interest in land’ that Oliver J in the Taylors Fashions case or Lord Kingsdown in Ramsden v Dyson had in mind† and so the claim failed. This requirement for a specific assurance narrowed the scope of operation of the doctrine and was inconsistent with previous Court of Appeal decisions such as Gillett v Holt and Jennings v Rice where a claimant had an expectation of a future interest in land. Lord Walker further restricted the doctrine by stating that the claimant must believe â€Å"that the assurance on which he or she relied was binding and irrevocable†. Therefore the claimant must not only believe that the landowner has made a promise, but also believe that the promise is legally binding. He made it clear that context was important. â€Å"In the domestic or family context, the typical claimant is not a business person and is not receiving legal advice†¦The focus is not on intangible legal rights but on the tangible property which he or she expects to get.† As the parties involved in Cobbe were â€Å"persons experienced in the property world, both parties knew that there was no legally binding contract, and that either was therefore free to discontinue the negotiations without legal liability†¦the fact is that he ran a commercial risk, with his eyes open† This restriction is also inconsistent with Gillett v Holt which â€Å"explicitly addressed, and rejected, the notion that the revocability of wills prevents a promise to make a will forming the basis of a proprietary estoppel claim.† Surprisingly it was Lord Walker who gave the leading judgement in that case and acknowledged here that â€Å"It may possibly be that some of the domestic cases might have been decided differently if the nature of the claimant’s belief had been an issue vigorously investigated in cross-examination.† Thus casting doubt on previous court of appeal authorities relating to testamentary promises . The reasoning in Cobbe left the doctrine in an uncertain position and â€Å"If taken literally, this reformulation would have curtailed the reach of estoppel, and perhaps that was the point†. Thorner v Major gave the House of Lords a chance to address these uncertainties and a further opportunity to clarify the doctrine definitively via the role of unconscionability. From the beginning the Lords made it clear that the decision in Cobbe had not â€Å"severely curtailed, or even virtually extinguished, the doctrine of proprietary estoppel (a rather apocalyptic view that has been suggested by some commentators).† Thorner dealt with proprietary estoppel in the domestic context. One cousin had worked unpaid on the other’s farm for nearly 30 years on the understanding that he would inherit the farm on his cousin’s death. The cousin died intestate and the claim of proprietary estoppel had been rejected by the Court of Appeal. One reason given for this failure was that the extent of the farm had fluctuated in the preceding years and so the interest the claimant expected to receive was not a sufficiently ‘certain interest’ as required following Cobbe. The Lords in Thorner made it clear that â€Å"the reasoning in Cobbe’s case†¦was directed to the unusual facts of that case† and that in Cobbe â€Å"there was no doubt about the physical identity of the property. However, there was total uncertainty as to the†¦property interest†¦In this case†¦there is†¦no doubt as to what was the subject of the assurance, namely the farm as it existed from time to time. Accordingly, the nature of the interest to be received by David was clear: it was the farm as it existed on Peter’s death. They confirmed that the assurances â€Å"should relate to identified property owned (or, perhaps, about to be owned) by the defendant.† and that â€Å"It would represent a regrettable and substantial emasculation of the beneficial principle of proprietary estoppel if it were artificially fettered so as to require the precise extent of the property the subject of the alleged estoppel to be strictly defined in every case.† Context is vital, whereas a specific certainty may be required in a commercial situation, this will not necessarily be required in a domestic context. The Court of Appeal had also required that the nature of the assurance be â€Å"clear and unequivocal† . This test for clarity of assurance was that required in promissory estoppel, and may have been adopted here due to the conflation of the two forms of estoppel by Lord Scott in Cobbe . The parties in Thorner were â€Å"taciturn and undemonstrative men† and the assurances mainly consisted of â€Å"oblique remarks† and therefore it was held that these assurances lacked the requisite certainty. The House of Lords loosened this restriction stating that â€Å"I would prefer to say †¦that to establish a proprietary estoppel the relevant assurance must be clear enough. What amounts to sufficient clarity, in a case of this sort, is hugely dependent on context† . As â€Å"the relationship between Peter and David was familial and personal, and neither of them†¦had much commercial experience†¦Peter made what were, in the circumstances, clear and unambiguous assurances that he would leave his farm to David, and David reasonably relied on, and reasonably acted to his detriment on the basis of, those assurances, over a long period.† The House of Lords had made it abundantly clear once again that everything is dependent on context. In a domestic context such as Thorner an oblique assurance may be ‘clear enough’ even though a commercial case such as in Cobbe may require a much more specific assurance. Lord Walker also rejected Lord Scott’s characterisation of estoppel â€Å"I have some difficulty with Lord Scott’s observation†¦that proprietary estoppel is a sub-species of promissory estoppel.† The House of Lord’s in Thorner also clarified that the correct approach for landowner’s intention was an objective test and that it was â€Å"enough that the meaning he conveyed would reasonably have been understood as intended to be taken seriously as an assurance which could be relied upon†¦It is not necessary that Peter should have known or foreseen the particular act of reliance†. The House of Lords allowed the proprietary estoppel claim to succeed even tho ugh there was no evidence that the claimant believed that the assurance was legally binding, therefore also rejecting Lord Walker’s restriction in Cobbe. Thorner had maintained a flexible approach to proprietary estoppel making it clear that everything was â€Å"hugely dependent on context†, re-affirming the holistic approach found in Gillett that â€Å"in the end the court must look at the matter in the round.† Lord Neuberger stated that â€Å"it appears to me unlikely in the extreme that Lord Scott was intending impliedly to disapprove any aspect of the reasoning or decision of the Court of Appeal in Gillett’s case† Thorner effectively placed the doctrine back in the position it stood before Cobbe. It was said that the decision in Thorner had â€Å"brought proprietary estoppel back from the brink. The apocalypse†¦has been averted and proprietary estoppel can continue to function as an independent source of rights. It can thus perform its vital role as a broad and flexible doctrine.† Thorner has clarified some of the uncertainties surrounding the traditional elements of proprietary estoppel that had been raised in Cobbe and followed in the Court of Appeal. It returned the formulation to a flexible and broad definition requiring ‘identifiable property’ that the assurance must be â€Å"in the circumstances, clear and unambiguous† and that the assurance must â€Å"reasonably have been understood as intended to be taken seriously as an assurance which could be relied upon. Thorner did not however say anything regarding role of unconscionability, only affirming the uncontroversial position taken by Cobbe, whilst confirming the flexibility of the doctrine. â€Å"Concentrating on the perceived morality of the parties’ behaviour can lead to an unacceptable degree of uncertainty of outcome, and hence I welcome the decision in Cobbe’s case†¦However, it is equally true that focussing on technicalities can lead to a degree of strictness inconsistent with the fundamental aims of equity† . Some commentators believe that this was an opportunity missed as â€Å"Lord Scott may have chosen the wrong train to ride in Yeoman’s Row, but it is not clear that he chose the wrong destination† Defining ‘unconscionability’ is a difficult task and commentators have their own competing theories. Dixon believes that â€Å"an estoppel is made out when a landowner makes a ‘double assurance’ – an assurance that the claimant will have some right over the representor’s land†¦combined with an assurance that the right will ensue even if the formalities necessary to convey that right are not complied with†¦Unconscionability exists when a ‘formality assurance’ is withdrawn after detrimental reliance † Balen and Knowles believe that â€Å"this â€Å"extra ingredient†, for so long described as â€Å"unconscionability†, requires the court to ask whether the basis, or condition, on which the claimant incurred her detriment has failed.† There is no consensus as to how unconscionability should be defined only that it should. It may be that the judiciary have missed an opportunity to clarify the doctrine or it could be that they have no desire to â€Å"define unconscionability and thereby limit the application of the doctrine†¦Uncertainty can be a benefit as well as a burden, and while unconscionability of itself cannot generate an estoppel, the claim can be denied despite t he presence of an assurance, reliance and detriment by judicious deployment of the ‘unconscionability’ card†.

Prom Nights from Hell Chapter Four

â€Å"Poor Sheeb, still locked in half-human form,† Jezebel teased. â€Å"I remember how good everything smells all the time. Ugh. And the temperature! Do the humans have to freeze everything with their wretched air-conditioning?† Sheba's face was smooth now, controlled. â€Å"I get by. There's plenty of misery to go around.† â€Å"That's the spirit! Just another few centuries, and you'll be in the big-time with me.† Sheba allowed a smirk to curl her lips. â€Å"Or maybe not quite so long.† One black eyebrow arched high against Jezebel's white forehead, raising almost to an ebony horn. â€Å"Is that so? Got something particularly evil up your sleeve, little sister?† Sheba didn't answer, tensing again as Jezebel sent her own thoughts snaking invisibly through the crowd inside the ballroom. Sheba locked her jaw, ready to strike back if Jezebel tried to undo any of her schemes. But Jezebel just looked, touching nothing. â€Å"Hmm,† Jezebel hummed to herself. â€Å"Hmm.† Sheba's fists clenched hard as Jezebel's search touched Cooper Silverdale, but again, Jezebel merely observed. â€Å"Well, well,† the horned demoness murmured. â€Å"Wow. Sheeb, I've got to say it, I'm impressed. You got a gun in. And a motivated hand-full of alcohol to weaken his free will!† The older demoness smiled with something that looked strangely like sincerity. â€Å"This is really evil. I mean, sure, a middle demon working homicide or mayhem or maybe riots could set something like this up at a prom, but a human-form child on misery detail? What are you, two, three hundred?† â€Å"Just one-eighty-six at my last spawn day,† Sheba answered brusquely, still wary. Jezebel whistled a tongue of flame through her lips. â€Å"Very impressed. And I can see that you aren't neglecting your assignment, either. That's one miserable crowd in there.† Jezebel laughed. â€Å"You've ended nearly every promising relationship, broken a few dozen lifelong friendships, made new enemies†¦ three, four, five fights brewing,† Jezebel counted, her mind with the humans. â€Å"You've even got the DJ listening to you! Such attention to detail. Ha-ha! I can count on one hand the humans who aren't completely wretched.† Sheba smiled grimly. â€Å"I'll get to them.† â€Å"Ghastly, Sheeb. Seriously nasty. You do our name proud. If every prom had a demoness like you involved, we'd own this world.† â€Å"Aw, Jez, you're making me blush,† Sheba said with heavy sarcasm. Jezebel laughed. â€Å"Of course, you've got a little help.† Jezebel's thoughts twisted in a circle around Celeste, who had just twisted herself around a new boy. Jilted girls cried, while the boys Celeste carelessly tossed aside flexed their fists and glowered wrathfully at their competition; burning with lust, each was determined that Celeste was finishing the night with him. Celeste was doing half the work tonight. â€Å"I use the tools available to me,† Sheba said. â€Å"What an ironic name! What an evil mind! Is she fully human?† â€Å"I passed her in the hall, just to check,† Sheba admitted. â€Å"Pure, clean human scent. Revolting.† â€Å"Huh. I would have sworn she had some demon in her ancestry. Good find. But, Sheba, asking a date? Pretty amateur, involving yourself physically that way.† Sheba's chin jabbed upward defensively, but she did not answer. Jezebel was right; it was crude and time-consuming to use one's human form rather than one's demon mind. However, it was the results that counted. Sheba's timely interference had kept Logan from discovering his true love. â€Å"Well, it in no way diminishes your accomplishments here tonight.† Jezebel's tone was conciliatory. â€Å"You pull this one off, and they'll put you in the baby demons' textbooks.† â€Å"Thanks,† Sheba snapped. Did Jezebel really think she could flatter Sheba into letting her guard down? Jezebel smiled, and her mists curled up on the edges, mirroring the expression. â€Å"A tip, Sheba. Keep them confused in there. If you can get Cooper to pull the trigger, then you might make some of these wannabe gangsters think they're under fire.† Jezebel shook her head in wonder. â€Å"You've got so much potential mayhem here. Of course, they'll bring in a riot demon if it really gets hot†¦ but you'd still get some of the credit for stirring it up.† Sheba grimaced, and glimmers of red flashed at her ears. What was Jezebel doing? Where was the trick? Her mind ran over and over the humans she was assigned to torment, but she could find no trace of Jezebel's distinct brimstone flavor in the ballroom. There was nothing but the misery Sheba had caused herself, and the few little pockets of repellent happiness that Sheba would attend to shortly. â€Å"You're certainly helpful tonight,† Sheba said, being deliberately insulting. Jezebel sighed, and there was something about the way her mists rolled back in on themselves that made her look†¦ embarrassed. For the first time, Sheba felt a hint of doubt about her assumptions. But Jezebel's motives had to be malicious. That's the only kind of motives demons had. With a rueful expression on her face, Jezebel asked quietly, â€Å"Is it so impossible to believe that I might want you to get promoted?† â€Å"Yes.† Jezebel sighed again. And again, the way her mists writhed in chagrin made Sheba uncertain. â€Å"Why?† Sheba demanded. â€Å"What do you get out of this?† â€Å"I know it's all wrong-or rather right-for me to be giving you advice you can work with. Not very evil of me.† Sheba nodded cautiously. â€Å"It's in our nature to trip up everyone, demons, humans-even angels if we get the chance. We're evil. Naturally we're going to backstab, whether it hurts our side or not. We wouldn't be demons if we didn't let envy, greed, lust, and wrath rule us.† Jezebel chuckled. â€Å"I remember-how many years ago was it? – Lilith almost got you booted back a few grades, didn't she?† Red fire smoldered in Sheba's eyes at the memory. â€Å"Almost.† â€Å"You handled it better than most. You're one of the very worst working misery right now, you know.† Flattery again? Sheba stiffened. Jezebel twisted her mists up with a finger, and then circled that finger so that the mists drew a smoky orb against the night sky. â€Å"There's a bigger picture, though, Sheba. Demons like Lilith can't see past the evil at hand. But there's a whole world out there, full of humans making millions of decisions every minute of the day and night. We can only be there to sway a fraction of those decisions. And sometimes, well, from where I'm standing, it feels like the angels are getting ahead†¦Ã¢â‚¬  â€Å"But, Jezebel!† Sheba gasped, shock breaking through her suspicion. â€Å"We're winning. Just watch the news-it's obvious we're winning.† â€Å"I know, I know. But even with all the wars and destruction†¦ it's odd, Sheba. There's still an awful lot of happiness out there. For every mugging I turn into a homicide, across town some angel has a bystander jumping another mugger to save the day. Or convincing the mugger to give up his wicked ways! Ugh. We're losing ground.† â€Å"But the angels are weak, Jezebel. Everyone knows that. They're so full of love that they can't concentrate. Half the time the stupid birdbrains fall in love with a human and trade their wings for a human body. Though why even an idiot angel would want this!† Sheba scowled down the length of her human form. So limiting. â€Å"I've never really understood the point of having to wear these around for half a millennium. I guess it's probably just to torture us, isn't it? The dark lords must enjoy watching us squirm.† â€Å"It's more than that. It's to make you really hate them. The humans, I mean.† Sheba stared at her. â€Å"Why would I need a reason? Hate is what I do.† â€Å"It happens, you know,† Jezebel said slowly. â€Å"The angels aren't the only ones to give it all up. There are demons who've traded their horns for a human.† â€Å"No!† Sheba's eyes widened, then narrowed in disbelief. â€Å"You're exaggerating. Now and then a demon shacks up with a human, but it's just to torment them. Just a bit of malicious fun.† Jezebel winced, swishing her mists into figure eights, but she didn't argue back. That's what made Sheba realize she was serious. Sheba swallowed hard. â€Å"Wow.† She couldn't imagine that. Taking all this delicious evil and throwing it away. Giving up a hard-earned pair of horns-horns that Sheba would destroy anything to have right now-and getting stuck with a weak, fully mortal body in return. Sheba eyed Jezebel's glistening onyx horns and frowned. â€Å"I don't understand how anyone could do that.† â€Å"Remember what you said about the angels? Getting distracted by love?† Jezebel asked. â€Å"Well, hate can be a distraction, too. Look at Lilith and her spiteful good deeds. Maybe it starts out with sticking it to the lesser demons, but who knows where it will lead? Virtue corrupts.† â€Å"I can't believe a few tricks against another demon could make you as stupid as a birdbrain,† Sheba mumbled under her breath. â€Å"Sheba, don't underestimate the angels,† Jezebel chastised. â€Å"You don't mess with them-you hear? Even a strong middle demon like me knows better than to lock horns with the feather-backs. They steer clear of us, and we steer clear of them. Let the Demon Lords deal with the angels.† â€Å"I know that, Jezebel. I wasn't spawned this decade.† â€Å"Sorry. I'm being helpful again.† She shuddered. â€Å"I just get so frustrated sometimes! Goodness and light on every side!† Sheba shook her head. â€Å"I don't see that. Misery is everywhere.† â€Å"Happiness is, too, sis. It's all over the place,† Jezebel said sadly. It was silent for a long moment as Jezebel's words lingered in the air. The sticky breeze washed across Sheba's skin. Miami was no hell, but it was comfortable at least. â€Å"Not at my prom!† Sheba retorted with sudden fierceness. Jezebel smiled widely-her teeth were black as the night sky. â€Å"That's just it-that's why I'm being so un-damnedly helpful. Because we need demonesses like you out there. We need the worst we can get on the front lines. Let the Liliths of the underworld mess around with petty tricks. Get me the Shebas on my side. Get me a thousand Shebas. We'll win this fight once and for all.† Sheba considered that for a moment, weighing the fierce purpose in Jezebel's voice. â€Å"That's evil in such a strange way. It almost sounds like good.† â€Å"Twisted, I know.† They laughed together for the first time. â€Å"Well, get back in there and destroy that prom.† â€Å"I'm on it. Go to hell, Jezebel.† Prom Nights from Hell Chapter Four Sibby Cumean started talking as soon as they got out of the airport. â€Å"How long have you been driving people around?† she asked Miranda. A year. â€Å"Did you grow up here?† â€Å"No.† â€Å"Do you have any brothers?† â€Å"No.† â€Å"Any sisters?† â€Å"N-no.† â€Å"Do you like driving?† â€Å"Yes.† â€Å"Do you have to wear that boring black suit?† â€Å"Yes.† â€Å"How old are you?† â€Å"Twenty.† â€Å"Um, not.† â€Å"Fine. Eighteen.† â€Å"Have you ever had sex?† Miranda cleared her throat. â€Å"I don't think that question is appropriate.† She heard herself sound like Dr. Trope, the assistant head of school, with the voice he used to tell her he wasn't listening to another excuse about why she was late getting back to campus, rules were made for a reason and that reason wasn't so she could flout them for her amusement; and speaking of late, did she plan at some point to decide what she was going to do next year or just irresponsibly forfeit her place at the several top-tier colleges she'd been accepted to, making the school look bad and herself look worse; and really he didn't know what had gotten into her recently, where was the Miranda Kiss who was going to be a doctor and save the world, who was a credit to the school and herself, rather than the one who was on her way to being expelled-is that what you really want, young lady? A voice she knew well since she seemed to have been hearing it at least once a week since early November. â€Å"You're a virgin,† Sibby announced, like she was confirming a sad fact she'd long suspected. â€Å"That's not-â€Å" â€Å"Do you at least have a boyfriend?† â€Å"Not at this-â€Å" â€Å"A girlfriend?† â€Å"No.† â€Å"Do you have any friends? You're not really very good at conversation.† Miranda was beginning to understand why the girl's relatives hadn't come to the airport for her. â€Å"I have lots of friends.† â€Å"Sure. I believe you. What do you do for fun?† â€Å"Answer questions.† â€Å"Please never try to be funny again.† Sibby leaned forward. â€Å"Have you ever thought of wearing some black eyeliner? It would be an improvement.† B polite! â€Å"Thanks.† â€Å"Can you pull up?† â€Å"Um, we're at a stoplight.† â€Å"Just go forward a tiny-perfect.† Looking in the side mirror, Miranda saw that Sibby had rolled down her window and was leaning out, saying now to the guys in the jeep next to them, â€Å"Where are you boys going?† The guys answered, â€Å"A little moonlight surfing. Want to come, goddess?† â€Å"I'm not a goddess. Do you think I look like one?† â€Å"I can't tell. Maybe if you take off your shirt.† â€Å"Maybe if you give me a kiss.† Miranda hit the button to roll up the window. â€Å"What are you doing?† Sibby demanded. â€Å"You could have broken my hand.† â€Å"Put your seat belt on, please.† â€Å"Put your seat belt on, please,† Sibby mimicked, slumping back into the seat. â€Å"Oh my gods, I was just trying to be sociable.† â€Å"Until we get to your destination, no more socializing.† â€Å"Have you listened to yourself recently? You sound like you're eighty, not eighteen.† She scowled at Miranda in the mirror. â€Å"I thought you were a driver, not a jailer.† â€Å"It's my job to make sure you get where you're going in a safe and timely manner. That's printed on the card you'll find in your seat pocket, by the way.† â€Å"How is kissing some boys going to make me unsafe?† â€Å"A million different ways. What if they have an invisible mouth fungus? Or DeathLip.† â€Å"There's no such thing as DeathLip.† â€Å"Are you sure?† â€Å"You're just jealous because I know how to have fun and you don't. Virgin.† Miranda rolled her eyes but kept quiet, listening to cell phone conversations from the cars behind them, a woman telling someone that the gardener was on his way, a guy saying in a mystical voice, â€Å"I see a mysterious stranger coming for you, I can't quite tell if it's a man or a woman.† Another man talking to someone about how he wanted to take that bitch out of the will and it didn't matter if she was his mother's favorite dog- She was interrupted suddenly by Sibby shouting, â€Å"Inn-Out Burger! We have to stop.† B accommodating! Miranda agreed to let Sibby order her own at the drive-through, then regretted it when she heard the girl saying to the guy taking the order, â€Å"Do I get a discount if I let you kiss me?† â€Å"Okay, seriously, were you raised on Crazycake? Why do you want to kiss all these guys you don't even know?† Miranda asked. â€Å"There aren't that many boys where I come from. And what does knowing them have to do with it? Kissing is great. I kissed four boys on the airplane. I'm hoping to make it twenty-five before the end of the day.† She added the two working the drive-through lane when she got her burger. â€Å"Are all hamburgers that delicious?† she asked when they were on the road again. Miranda glanced at her in the rearview mirror. â€Å"You've never had a burger before? Where do you live?† â€Å"The mountains,† Sibby answered quickly, and Miranda picked up a slight rise in her heart rate, suggesting that she was lying and not used to it. Which seemed hugely unlikely-the not-used-to-it part-for someone who had a case of acute Boy Crazy like this girl. Her parents couldn't possibly let her run around- Oh So Very Much Not Your Problem, Miranda reminded herself. B discreet. Sibby tried to solicit kisses from four other guys as they drove. They were a mile from the drop-off point and Miranda was thinking that the ride could not be over soon enough when Sibby shrieked, â€Å"Oh my gods, a doughnut store! I've always wanted to try doughnuts, too. Can we stop? Pleasepleasepleasepleaseplease?† They were already almost an hour late but Miranda couldn't deny anyone a doughnut. Even someone who said, â€Å"Oh my gods.† But pulling in, she saw a group of guys sitting at a table inside and decided that it would be dangerous to let Sibby near them if she wanted to get out of there in under forty minutes. â€Å"I'll go in and get them, you stay here.† Sibby had seen the guys, too. â€Å"No way, I'm coming in.† â€Å"Either your butt stays in the car, Kissing Bandit, or the doughnuts stay in the store.† â€Å"I don't think that's a nice way to talk to customers.† â€Å"Feel free to use my phone to file a complaint while I'm inside. Do we have a deal?† â€Å"Fine. But will you at least roll down the window?† Miranda hesitated. Sibby said, â€Å"Look, Grandma, I promise I'll keep my butt in the car, I just don't want to suffocate. Gods.† When Miranda came out, Sibby had wedged herself in the window with her body and legs outside the car and her rear hanging back into it, and was deeply involved in kissing a blond guy. â€Å"Excuse me,† Miranda said, tapping the guy on the shoulder. He turned around kind of hazy, looked her up and down. â€Å"Hello, dream girl. You want a kiss, too? I could do something really special with lips like yours. You wouldn't even have to pay me a dollar.† â€Å"Thanks, but no.† Looking at Sibby now. â€Å"I thought we'd agreed that-â€Å" † – my butt would stay in the car. Where, if you bothered to look, you would see it is.† Miranda turned away so Sibby wouldn't see her crack up. She handed Sibby the doughnuts and slid into the driver's seat. Once Sibby had wiggled back through the window, Miranda caught her eye in the rearview. â€Å"You were paying guys to kiss you?† â€Å"So what?† Sibby glared. â€Å"Not all of us can get kissed for free.† More glaring, then, â€Å"You barely have boobs. My boobs are bigger than yours. It makes no sense.† Sibby got quiet, not even eating her doughnut. From time to time she'd sigh dramatically. Miranda started feeling a little sorry. Maybe she had been acting like a grandma. She looked at How to Get-And Kiss-Your Guy on the seat next to her. Maybe you're jealous she's four years younger than you but has already kissed more guys in one day than you'll probably date in your whole life even if you get a boob job and live to be two trillion. Shut up, U-Suck channel. She should be nice, make conversation. â€Å"How many kisses is it total now?† Sibby kept her eyes on her lap. â€Å"Ten.† Looking up to add, â€Å"But I only paid six of them. And one of them I only gave a quarter.† â€Å"Nice work.† Miranda saw Sibby look up suspiciously, like she thought she was being made fun of, decide she wasn't, and start picking at her doughnut. After a while she said, â€Å"Can I ask you a question?† â€Å"You're asking permission now?† â€Å"For real, just please stop trying to be funny. It's painful.† â€Å"Thanks for the hot tip. Did you have a question or-â€Å" â€Å"Why didn't you want to kiss that boy back there? The one who wanted to kiss you?† â€Å"I guess he's not my type.† â€Å"What's your type?† Miranda thought of Deputy Reynolds-blue eyes and cleft jaw and shaggy blond hair, getting up every morning to go surfing. The kind of guy who always wore sunglasses or looked at you with his eyes half closed and was too cool for smiling. Then pictured Will with his dark, maple-syrup-color skin, short curly hair, huge boyish smile, and abs that rippled when he stood talking, shirtless, with the other players after lacrosse practice, body glimmering in the sun, his laugh ringing out and making her feel like she felt when she saw butter melting on perfectly cooked Belgian waffles. Not that she routinely jumped up onto the roof of the marine biology lab when no one was looking to watch this. (Weekly.) â€Å"I don't know, it's more a feeling than a type,† Miranda said finally. â€Å"How many boys have you kissed? A hundred?† â€Å"Uh, no.† â€Å"Two hundred?† Miranda felt herself blushing and hoped Sibby couldn't see. â€Å"Keep guessing.† They pulled up to the address she'd been given, an hour and fifteen minutes later than they should have, the first time she'd ever dropped a client off late. When Miranda opened the car door for her, Sibby asked, â€Å"Is kissing a boy who's your type really different than kissing just any boy?† â€Å"It's complicated.† Miranda was surprised at how relieved she was that she wouldn't have to go into it more, admit to this girl that, actually, she had no idea. The place looked more like a government safe house for witnesses than a home, she thought, walking Sibby to the door. It was like the dictionary definition of nondescript, sandwiched between a house with Snow White and the Seven Dwarves enacting the Nativity on the front lawn on one side, and one with a pink-and-orange swing set on the other. The only thing you noticed about this house was that there were thick curtains hanging in the front windows so you couldn't see in, and a six-foot-tall solid wood fence blocking off the backyard so you couldn't get in. The street was filled with noises-Miranda heard BBQs sizzling, conversations, someone watching Beauty and the Beast in Spanish-but this house was silent, as though it had been soundproofed. She registered a low humming coming from the side, like an air conditioner but not quite. Glancing up, she saw that none of the power lines connected to this house. None of the phone lines, either. A generator. Whoever lived here was living off the grid. All in all, the whole place was really cozy, if cozy meant creepy and cultish. And the woman who opened the front door? Exactly what you'd expect of someone creepy and cultish, Miranda thought. She had graying hair pulled back in a loose bun and was wearing a long skirt and kind of shapeless sweater. She could have been anywhere from thirty to sixty years old, it was impossible to tell because she was wearing a pair of huge bifocals with unflattering square frames that magnified her eyes and covered half her face. She looked completely harmless, like a schoolteacher who'd dedicated her life to caring for an aging relative and whose one indulgence was a secret crush on Mr. Rochester from Jane Eyre. Or almost like that. Like that was the look she'd been going for. But there was something wrong, some tiny thing that did not quite match, one tiny detail that wasn't right. So. Not. Your. Business. Miranda said good-bye, took her $1.00 tip-â€Å"Because you were really quite late, dear†-and drove away. She was half a block away when she slammed on the brakes and sprinted back to the house. Prom Nights from Hell Chapter Four Sibby Cumean started talking as soon as they got out of the airport. â€Å"How long have you been driving people around?† she asked Miranda. A year. â€Å"Did you grow up here?† â€Å"No.† â€Å"Do you have any brothers?† â€Å"No.† â€Å"Any sisters?† â€Å"N-no.† â€Å"Do you like driving?† â€Å"Yes.† â€Å"Do you have to wear that boring black suit?† â€Å"Yes.† â€Å"How old are you?† â€Å"Twenty.† â€Å"Um, not.† â€Å"Fine. Eighteen.† â€Å"Have you ever had sex?† Miranda cleared her throat. â€Å"I don't think that question is appropriate.† She heard herself sound like Dr. Trope, the assistant head of school, with the voice he used to tell her he wasn't listening to another excuse about why she was late getting back to campus, rules were made for a reason and that reason wasn't so she could flout them for her amusement; and speaking of late, did she plan at some point to decide what she was going to do next year or just irresponsibly forfeit her place at the several top-tier colleges she'd been accepted to, making the school look bad and herself look worse; and really he didn't know what had gotten into her recently, where was the Miranda Kiss who was going to be a doctor and save the world, who was a credit to the school and herself, rather than the one who was on her way to being expelled-is that what you really want, young lady? A voice she knew well since she seemed to have been hearing it at least once a week since early November. â€Å"You're a virgin,† Sibby announced, like she was confirming a sad fact she'd long suspected. â€Å"That's not-â€Å" â€Å"Do you at least have a boyfriend?† â€Å"Not at this-â€Å" â€Å"A girlfriend?† â€Å"No.† â€Å"Do you have any friends? You're not really very good at conversation.† Miranda was beginning to understand why the girl's relatives hadn't come to the airport for her. â€Å"I have lots of friends.† â€Å"Sure. I believe you. What do you do for fun?† â€Å"Answer questions.† â€Å"Please never try to be funny again.† Sibby leaned forward. â€Å"Have you ever thought of wearing some black eyeliner? It would be an improvement.† B polite! â€Å"Thanks.† â€Å"Can you pull up?† â€Å"Um, we're at a stoplight.† â€Å"Just go forward a tiny-perfect.† Looking in the side mirror, Miranda saw that Sibby had rolled down her window and was leaning out, saying now to the guys in the jeep next to them, â€Å"Where are you boys going?† The guys answered, â€Å"A little moonlight surfing. Want to come, goddess?† â€Å"I'm not a goddess. Do you think I look like one?† â€Å"I can't tell. Maybe if you take off your shirt.† â€Å"Maybe if you give me a kiss.† Miranda hit the button to roll up the window. â€Å"What are you doing?† Sibby demanded. â€Å"You could have broken my hand.† â€Å"Put your seat belt on, please.† â€Å"Put your seat belt on, please,† Sibby mimicked, slumping back into the seat. â€Å"Oh my gods, I was just trying to be sociable.† â€Å"Until we get to your destination, no more socializing.† â€Å"Have you listened to yourself recently? You sound like you're eighty, not eighteen.† She scowled at Miranda in the mirror. â€Å"I thought you were a driver, not a jailer.† â€Å"It's my job to make sure you get where you're going in a safe and timely manner. That's printed on the card you'll find in your seat pocket, by the way.† â€Å"How is kissing some boys going to make me unsafe?† â€Å"A million different ways. What if they have an invisible mouth fungus? Or DeathLip.† â€Å"There's no such thing as DeathLip.† â€Å"Are you sure?† â€Å"You're just jealous because I know how to have fun and you don't. Virgin.† Miranda rolled her eyes but kept quiet, listening to cell phone conversations from the cars behind them, a woman telling someone that the gardener was on his way, a guy saying in a mystical voice, â€Å"I see a mysterious stranger coming for you, I can't quite tell if it's a man or a woman.† Another man talking to someone about how he wanted to take that bitch out of the will and it didn't matter if she was his mother's favorite dog- She was interrupted suddenly by Sibby shouting, â€Å"Inn-Out Burger! We have to stop.† B accommodating! Miranda agreed to let Sibby order her own at the drive-through, then regretted it when she heard the girl saying to the guy taking the order, â€Å"Do I get a discount if I let you kiss me?† â€Å"Okay, seriously, were you raised on Crazycake? Why do you want to kiss all these guys you don't even know?† Miranda asked. â€Å"There aren't that many boys where I come from. And what does knowing them have to do with it? Kissing is great. I kissed four boys on the airplane. I'm hoping to make it twenty-five before the end of the day.† She added the two working the drive-through lane when she got her burger. â€Å"Are all hamburgers that delicious?† she asked when they were on the road again. Miranda glanced at her in the rearview mirror. â€Å"You've never had a burger before? Where do you live?† â€Å"The mountains,† Sibby answered quickly, and Miranda picked up a slight rise in her heart rate, suggesting that she was lying and not used to it. Which seemed hugely unlikely-the not-used-to-it part-for someone who had a case of acute Boy Crazy like this girl. Her parents couldn't possibly let her run around- Oh So Very Much Not Your Problem, Miranda reminded herself. B discreet. Sibby tried to solicit kisses from four other guys as they drove. They were a mile from the drop-off point and Miranda was thinking that the ride could not be over soon enough when Sibby shrieked, â€Å"Oh my gods, a doughnut store! I've always wanted to try doughnuts, too. Can we stop? Pleasepleasepleasepleaseplease?† They were already almost an hour late but Miranda couldn't deny anyone a doughnut. Even someone who said, â€Å"Oh my gods.† But pulling in, she saw a group of guys sitting at a table inside and decided that it would be dangerous to let Sibby near them if she wanted to get out of there in under forty minutes. â€Å"I'll go in and get them, you stay here.† Sibby had seen the guys, too. â€Å"No way, I'm coming in.† â€Å"Either your butt stays in the car, Kissing Bandit, or the doughnuts stay in the store.† â€Å"I don't think that's a nice way to talk to customers.† â€Å"Feel free to use my phone to file a complaint while I'm inside. Do we have a deal?† â€Å"Fine. But will you at least roll down the window?† Miranda hesitated. Sibby said, â€Å"Look, Grandma, I promise I'll keep my butt in the car, I just don't want to suffocate. Gods.† When Miranda came out, Sibby had wedged herself in the window with her body and legs outside the car and her rear hanging back into it, and was deeply involved in kissing a blond guy. â€Å"Excuse me,† Miranda said, tapping the guy on the shoulder. He turned around kind of hazy, looked her up and down. â€Å"Hello, dream girl. You want a kiss, too? I could do something really special with lips like yours. You wouldn't even have to pay me a dollar.† â€Å"Thanks, but no.† Looking at Sibby now. â€Å"I thought we'd agreed that-â€Å" † – my butt would stay in the car. Where, if you bothered to look, you would see it is.† Miranda turned away so Sibby wouldn't see her crack up. She handed Sibby the doughnuts and slid into the driver's seat. Once Sibby had wiggled back through the window, Miranda caught her eye in the rearview. â€Å"You were paying guys to kiss you?† â€Å"So what?† Sibby glared. â€Å"Not all of us can get kissed for free.† More glaring, then, â€Å"You barely have boobs. My boobs are bigger than yours. It makes no sense.† Sibby got quiet, not even eating her doughnut. From time to time she'd sigh dramatically. Miranda started feeling a little sorry. Maybe she had been acting like a grandma. She looked at How to Get-And Kiss-Your Guy on the seat next to her. Maybe you're jealous she's four years younger than you but has already kissed more guys in one day than you'll probably date in your whole life even if you get a boob job and live to be two trillion. Shut up, U-Suck channel. She should be nice, make conversation. â€Å"How many kisses is it total now?† Sibby kept her eyes on her lap. â€Å"Ten.† Looking up to add, â€Å"But I only paid six of them. And one of them I only gave a quarter.† â€Å"Nice work.† Miranda saw Sibby look up suspiciously, like she thought she was being made fun of, decide she wasn't, and start picking at her doughnut. After a while she said, â€Å"Can I ask you a question?† â€Å"You're asking permission now?† â€Å"For real, just please stop trying to be funny. It's painful.† â€Å"Thanks for the hot tip. Did you have a question or-â€Å" â€Å"Why didn't you want to kiss that boy back there? The one who wanted to kiss you?† â€Å"I guess he's not my type.† â€Å"What's your type?† Miranda thought of Deputy Reynolds-blue eyes and cleft jaw and shaggy blond hair, getting up every morning to go surfing. The kind of guy who always wore sunglasses or looked at you with his eyes half closed and was too cool for smiling. Then pictured Will with his dark, maple-syrup-color skin, short curly hair, huge boyish smile, and abs that rippled when he stood talking, shirtless, with the other players after lacrosse practice, body glimmering in the sun, his laugh ringing out and making her feel like she felt when she saw butter melting on perfectly cooked Belgian waffles. Not that she routinely jumped up onto the roof of the marine biology lab when no one was looking to watch this. (Weekly.) â€Å"I don't know, it's more a feeling than a type,† Miranda said finally. â€Å"How many boys have you kissed? A hundred?† â€Å"Uh, no.† â€Å"Two hundred?† Miranda felt herself blushing and hoped Sibby couldn't see. â€Å"Keep guessing.† They pulled up to the address she'd been given, an hour and fifteen minutes later than they should have, the first time she'd ever dropped a client off late. When Miranda opened the car door for her, Sibby asked, â€Å"Is kissing a boy who's your type really different than kissing just any boy?† â€Å"It's complicated.† Miranda was surprised at how relieved she was that she wouldn't have to go into it more, admit to this girl that, actually, she had no idea. The place looked more like a government safe house for witnesses than a home, she thought, walking Sibby to the door. It was like the dictionary definition of nondescript, sandwiched between a house with Snow White and the Seven Dwarves enacting the Nativity on the front lawn on one side, and one with a pink-and-orange swing set on the other. The only thing you noticed about this house was that there were thick curtains hanging in the front windows so you couldn't see in, and a six-foot-tall solid wood fence blocking off the backyard so you couldn't get in. The street was filled with noises-Miranda heard BBQs sizzling, conversations, someone watching Beauty and the Beast in Spanish-but this house was silent, as though it had been soundproofed. She registered a low humming coming from the side, like an air conditioner but not quite. Glancing up, she saw that none of the power lines connected to this house. None of the phone lines, either. A generator. Whoever lived here was living off the grid. All in all, the whole place was really cozy, if cozy meant creepy and cultish. And the woman who opened the front door? Exactly what you'd expect of someone creepy and cultish, Miranda thought. She had graying hair pulled back in a loose bun and was wearing a long skirt and kind of shapeless sweater. She could have been anywhere from thirty to sixty years old, it was impossible to tell because she was wearing a pair of huge bifocals with unflattering square frames that magnified her eyes and covered half her face. She looked completely harmless, like a schoolteacher who'd dedicated her life to caring for an aging relative and whose one indulgence was a secret crush on Mr. Rochester from Jane Eyre. Or almost like that. Like that was the look she'd been going for. But there was something wrong, some tiny thing that did not quite match, one tiny detail that wasn't right. So. Not. Your. Business. Miranda said good-bye, took her $1.00 tip-â€Å"Because you were really quite late, dear†-and drove away. She was half a block away when she slammed on the brakes and sprinted back to the house. Prom Nights from Hell Chapter Four I laughed. â€Å"But you girls go on, knock yourselves out,† he said. â€Å"I've actually got an errand to run.† â€Å"You're leaving?† Yun Sun said. â€Å"What about the pizza?† I said. He opened his wallet and laid a twenty-dollar bill on the coffee table. â€Å"It'll be here in thirty minutes. My treat.† Yun Sun shook her head. â€Å"And again I say: You're leaving?. You're not even staying to eat?† â€Å"There's something I need to do,† he said. My heart constricted. I ached to keep him here, even if just for a little longer. I darted back to the kitchen and pulled Madame Z's corsage-no, my corsage-out of my bag. â€Å"At least wait till I've made my wish,† I said. He looked amused. â€Å"Fine, wish away.† I hesitated. The den was warm and cozy, pizza was on the way, and I had the two greatest friends in the world. What else did I truly want? Duh, the grasping part of my brain told me. Prom, of course. I wanted Will to ask me to prom. Maybe it was selfish to have so much and still want more, but I pushed that line of reasoning away. Because look at him, I thought. Those kind brown eyes, that lopsided smile. Those ridiculously angelic curls. The entire sweetness and goodness that was Will. He hummed the Jeopardy! theme song. I raised the corsage. â€Å"I wish for the boy I love to ask me to prom,† I said. â€Å"And there you have it, folks!† Will cried. He was far too euphoric. â€Å"And what boy wouldn't want to take her to prom, our fabulous Frankie? Now we'll just have to wait and see, won't we, whether her wish will come-â€Å" Yun Sun cut him off. â€Å"Frankie? Are you okay?† â€Å"It moved,† I said, cringing away from the corsage, which I'd flung to the floor. My skin was clammy. â€Å"I swear to God, it moved when I made the wish. And that smell! Do you smell it?† â€Å"Noooo,† she said. â€Å"What smell?† â€Å"You smell it, Will. Don't you?† He grinned, still on whatever high he'd been on since†¦ well, since Madame Z warned him away from heights. A clap of thunder rumbled, and he shoved my shoulder. â€Å"Next you're going to blame the storm on the evil wish fairies, aren't you?† he said. â€Å"Or, no! You're going to go to bed tonight, and tomorrow you'll tell us you found a hunched and skulking creature on your comforter, smiling a twisted smile!† â€Å"Like rotting flowers,† I said. â€Å"You honestly don't smell it? You're not playing with me?† Will dug his keys out of his pocket. â€Å"See you on the flip side, homies. And, Frankie?† â€Å"What?† Another boom of thunder shook the house. â€Å"Don't give up hope,† he said. â€Å"Good things come to those who wait.† I watched through the window as he dashed to his truck. The rain was coming down in sheets. Then I turned to Yun Sun, a balloony feeling pushing everything else away. â€Å"Did you hear what he said?† I grabbed her hands. â€Å"Oh my God, do you think it means what I think it means?† â€Å"What else could it mean?† Yun Sun said. â€Å"He's going to ask you to prom! He's just†¦ I don't know. Trying to make a big production out of it!† â€Å"What do you think he's going to do?† â€Å"No idea. Hire a skywriter? Send a singing telegram?† I squealed. She squealed. We jumped about in a frenzy. â€Å"Got to hand it to you, the wish thing was brilliant,† she said. She flicked her finger to indicate giving Will the push he needed. â€Å"And the rotting flowers? Verrrry dramatic.† â€Å"I honestly did smell it, though,† I said. â€Å"Ha-ha.† â€Å"I did.† She looked at me and shook her head, amused. Then she looked at me again. â€Å"Well, it must have been your imagination,† she said. â€Å"I guess,† I said. I picked the corsage up off the floor, holding it gingerly between my thumb and forefinger. I took it to the bookshelf and dropped it behind a row of books, glad to have it out of sight. The next morning I trotted downstairs, hoping foolishly to find†¦ I don't know. Hundreds of M spelling out my name? Pink hearts sketched in silly string on the windows? Instead, I found a dead bird. Its tiny body lay on the welcome mat, as if it had flown into the door during the storm and bashed its brains in. I scooped it up with a paper towel and tried not to feel its soft weight as I delivered it to the outside trash bin. â€Å"I'm sorry, little bird, so pretty and sweet,† I said. â€Å"Fly to heaven.† I dropped in the corpse, and the lid slammed shut with a bang. I returned inside to the sound of the ringing phone. Probably Yun Sun, wanting an update. She'd left with Jeremy at eleven last night, after making me swear to tell her the minute Will made his bold move. â€Å"Hey, sweetie,† I said, after glancing at the caller ID and seeing that, yep, I was right. â€Å"No news yet-sorry.† â€Å"Frankie†¦Ã¢â‚¬  Yun Sun said. â€Å"I've been thinking about Madame Z, though. Her whole don't-mess-with-fate mumbo jumbo.† â€Å"Frankie-â€Å" â€Å"Because how could Will asking me to prom lead to anything bad?† I walked to the freezer and grabbed a box of frozen waffles. â€Å"Spit's going to fly from his mouth and land on me? He'll bring me flowers, and a bee'll zip out and sting me?† â€Å"Frankie, stop. Didn't you watch the morning news?† â€Å"On a Saturday? I don't think so.† Yun Sun made a gulping sound. â€Å"Yun Sun, are you crying?† â€Å"Last night†¦ Will climbed the watertower,† she said. â€Å"What?!† The watertower was easily three hundred feet tall, with a sign at the bottom prohibiting anyone from ascending. Will always talked about climbing to the top, but he was such a rule-follower that he never had. â€Å"And the railing must have been wet†¦ or maybe it was lightning, they don't yet know†¦Ã¢â‚¬  â€Å"Yun Sun. What happened?† â€Å"He was spray painting something on the tower, the stupid idiot, and-â€Å" â€Å"Spray painting? Will?† â€Å"Frankie, will you shut up? He fell! He fell off the watertower!† I gripped the phone. â€Å"Jesus. Is he okay?† Yun Sun was unable to talk for sobbing. Which I understood, sure. Will was her friend, too. But I needed her to pull it together. â€Å"Is he in the hospital? Can I go visit him? Yun Sun!† There was wailing, and then a shuffling sound. Mrs. Yomiko took over. Prom Nights from Hell Chapter Four â€Å"You don't understand.† Lila tosses back her long blond hair. â€Å"He's not a tick, Mary. Sebastian loves me too much to bite me. But I know I can change his mind. Because he wants to be with me forever, as much as I want to be with him forever. I know it. And after tomorrow night, we will be together forever.† â€Å"What's tomorrow night?† Adam wants to know. â€Å"The prom,† I say woodenly. â€Å"Right,† Lila prattles on. â€Å"Sebastian's taking me. And though he doesn't know it yet, he's going to give in to me there. Just one bite and I'll have eternal life. Come on, you guys, how cool is that? Wouldn't you want to live forever? I mean, if you could?† â€Å"Not that way,† I say. Something inside of me aches. Aches for Lila, and aches for all the girls who've gone before her. And will come after her, too, if I don't do something about it. â€Å"He's meeting you at the dance?† I force myself to ask her. It's hard to speak, because all I want to do is cry. â€Å"Right,† Lila says. Her face still has the same vacant expression she wore inside the club, as well as earlier today in the lunchroom. â€Å"He'll never be able to resist me-not in my new Roberto Cavalli gown, with my neck all exposed beneath the silver light of the full moon†¦Ã¢â‚¬  â€Å"I think I'm going to throw up,† Ted volunteers. â€Å"No, you're not,† I say. â€Å"You're going to take Lila home. Here.† I reach into my satchel and pull out a crucifix and two containers of holy water, then hand them to him. â€Å"If Drake shows up-although I don't think he will-throw these at him. Then get yourself home, after you've dropped off Lila.† Ted looks down at what I've shoved into his hands. â€Å"Wait. That's it?† he wants to know. â€Å"We're just going to let him kill her?† â€Å"Not kill,† Lila corrects him cheerfully. â€Å"Turn me. Into one of his kind.† â€Å"We aren't going to do anything,† I say. â€Å"You guys are going to go home and leave this to me. I've got it under control. Just make sure Lila gets back safely. She should be all right until the dance. Evil spirits cannot enter an inhabited house unless invited!† I narrow my eyes at Lila. â€Å"You didn't invite him inside, did you?† â€Å"Whatever,† Lila says, tossing her head. â€Å"Like my dad wouldn't go too ballistic if he found a guy in my room.† â€Å"See? Go home. You, too,† I add, to Adam. Ted takes Lila by the arm and begins to lead her away. But Adam, to my surprise, stays where he is, his hands buried deep in his pockets. â€Å"Um,† I say to him. â€Å"Is there something I can do for you?† â€Å"Yes,† Adam says calmly. â€Å"You can start at the beginning. I want to know everything. Because if what you're telling me is true, if it weren't for me, you'd be a speck on the wall in the club back there. So start talking.† Adam If you had told me just an hour or two ago that I'd be ending my evening with a trip to Mary-from-U.S.-History-class's penthouse apartment over in the East Seventies†¦ well, I'd have told you that you were high. But that's exactly where I find myself, following Mary past her sleepy doorman (who doesn't raise so much as an eyebrow at her crossbow), and then up the elevator to her place, which is decorated in mid-nineteenth-century Victorian chic-at least as near as I can judge, considering all the furniture looks like it came out of one of those boring miniseries my mom likes to watch on PBS, featuring girls named Violet or Hortense or whatever. There are books everywhere-and not Dan Brown paperbacks, either, but big, heavy books, with titles like Demonology in Seventh-century Greece and A Guide to Necromancy. I look around, but I don't see a plasma screen or an LCD. Not even a regular TV. â€Å"Are your parents professors or something?† I ask Mary as she throws down the crossbow and heads to the kitchen, where she pulls open the fridge and reaches for two Cokes, one of which she hands to me. â€Å"Something like that,† Mary says. This is what she's been like the whole way to her place: not exactly brimming with the explanations. Not that it matters, though, since I already told her I'm not leaving until I get the whole story. The thing is, I really don't know what to think about all this so far. On the one hand, I'm relieved Drake isn't who I thought he was-Mary's ex-boyfriend. On the other hand†¦ a vampire?. â€Å"Come on,† Mary says, and I follow her because†¦ well, what else am I supposed to do? I don't know what I'm doing here. I don't believe in vampires. I think Lila's just gotten herself involved with one of those freaky goth dudes I saw on Law & Order that one time. Although Mary's question-â€Å"Then how do you explain his disappearance from the dance floor into thin air like that?† – bugs me. How did the guy do that? Then again, there are tons of questions like that one that I don't have the answers for. Like this new one that occurred to me: How can I get Mary to look at me the way Lila looked at that guy, Drake? Life is full of mysteries, as my dad likes to say, many of which are also wrapped up in enigmas. Mary leads me down a dark hallway toward a partly open door, from which light spills. She taps on the door, then says, â€Å"Dad? Can we come in?† A gruff voice says, â€Å"By all means.† And I follow Mary into the strangest room I've ever seen. At least in a penthouse apartment on the Upper East Side. It's a laboratory. There are test tubes and beakers and vials everywhere. Standing in front of some of them is a tall, white-haired-professor type in a bathrobe, messing around with a concoction in a clear container that's bright green and vigorously generating large amounts of smoke. The old dude looks up from this and smiles as Mary comes into the room, his green-eyed gaze-a lot like Mary's-darting toward me curiously. â€Å"Well, hello,† the guy says. â€Å"I see you've brought a friend home. I'm so glad. I've been thinking lately that you spend far too much time alone, young lady.† â€Å"Dad, this is Adam,† Mary says casually. â€Å"He sits behind me in U.S. History. We're going to my room to do homework.† â€Å"How nice,† Mary's father says. It doesn't seem to occur to him that the last thing a guy my age is likely to be doing in a girl's bedroom at two in the morning is homework. â€Å"Don't study too hard, now, children.† â€Å"We won't,† Mary says. â€Å"Come on, Adam.† â€Å"Good night, sir,† I say to Mary's dad, who beams at me before turning back to his smoking beaker. â€Å"Okay,† I say to Mary as she leads me down the hall once more, this time to her room†¦ which is surprisingly utilitarian for a girl's bedroom, containing only a large bed, a dresser, and a desk. Unlike in Veronica's room, everything is put away, except for a laptop and an MP3 player. I take a quick look at Mary's play list when she's busy rifling around in the closet for something. Mostly rock, some R&B, and a little rap. No emo, though. Thank God. â€Å"What's going on? What's your dad doing with all that stuff?† â€Å"Looking for a cure,† Mary says from the closet, her voice muffled. I've moved across the ornate Persian carpet toward her bed. There's a framed photo on her nightstand. It's of a pretty woman, squinting into the sunlight and smiling. Mary's mother. I don't know how I know it. I just do. â€Å"A cure for what?† I ask, picking up the photo for a closer look. Yep, there they are. Mary's lips. Which, I haven't been able to stop noticing, are kind of curled up at the ends. Even when she's mad. â€Å"Vampirism,† Mary says. She emerges from the closet holding a long red dress. It's wrapped in clear plastic from the dry cleaner's. â€Å"Uh,† I say, â€Å"I hate to be the one to tell you this, Mary. But there's no such thing as vampires. Or vampirism. Or whatever it is.† â€Å"Oh yeah?† The ends of Mary's mouth are curled up even more than usual. â€Å"Vampires were just made up by that guy.† She's laughing at me. I don't mind, though, because it's Mary. It's better than her ignoring me, which is what she's done for most of the time I've known her. â€Å"That guy who wrote Dracula. Right?† â€Å"Bram Stoker did not make up vampires,† Mary says, the smile vanishing. â€Å"He didn't even make up Dracula. Who's an actual historical figure, by the way.† â€Å"Yeah, but a dude who drinks blood and can turn into a bat? Come on.† â€Å"Vampires exist, Adam,† Mary says quietly. I like how she says my name. I like it so much that I don't even notice at first that she's staring at the photo I'm holding. â€Å"And so do their victims.† I follow the direction of her gaze. And nearly drop the photo. â€Å"Mary,† I say. Because it's all I can think of to say. â€Å"Your†¦ your mom? Is she†¦ did she†¦Ã¢â‚¬  â€Å"She's still alive,† Mary says, turning to throw the red dress, in its slippery clear plastic bag, onto the bed. â€Å"If you can call it living,† she adds, almost to herself. â€Å"Mary†¦Ã¢â‚¬  I say in a different tone of voice. I can't believe it. And yet I do. There's something in her face that makes it clear she's not lying. Also something that makes me long to wrap her in my arms. Which Veronica would say is sexist. But there you go. I let go of the lip I've started chewing. â€Å"Is that why your dad-â€Å" â€Å"He wasn't always like that,† she says, not looking at me. â€Å"He used to be different, when Mom was here. He†¦ he thinks he can find a chemical cure for it.† She sinks onto the bed beside the dress. â€Å"He doesn't want to believe that there's only one way to get her back. And that's killing the vampire who made her into one.† â€Å"Drake,† I say, sinking down onto the bed beside her. It all makes sense now. I guess. â€Å"No,† Mary says with a quick shake of her head. â€Å"His father. Who happened to stick with the original family name of Dracula. His son just thinks Drake sounds a little less pretentious and more modern.† â€Å"So†¦ why were you trying to kill Dracula's kid, if his dad is the one who†¦Ã¢â‚¬  I can't even bring myself to say it. Fortunately, I don't have to. Mary's shoulders are hunched. â€Å"If killing his only kid doesn't get Dracula to come out of hiding so I can kill him, too, I don't know what will.† â€Å"Won't that be, uh†¦ kind of dangerous?† I ask. I can't believe I'm sitting here talking about this. But I can't believe I'm in Mary-from-U.S.-History's bedroom, either. â€Å"I mean, isn't Dracula, like, the head of the whole operation?† â€Å"Yes,† Mary says, looking down at the photo I've laid between us. â€Å"And when he's gone, Mom will finally be free.† And Mary's dad won't have to worry about finding a cure for vampirism anymore, I think, but don't say out loud. â€Å"Why didn't Drake just, uh, turn Lila tonight?† I ask. Because this has been bothering me. Among other things. â€Å"I mean, back at the club?† â€Å"Because he likes to play with his food,† Mary says emotionlessly. â€Å"Just like his dad.†

Analysis Of Recruitment Methods At Tata Consultancy Services

Analysis Of Recruitment Methods At Tata Consultancy Services Introduction to Recruitment Indian business industry is experiencing vibrant changes in recent times as never endured in the past. Range of national economy resulted from a steady growth in business industry. This growth finally depends up on potential human resources of the organizations. Customer focus, cost advantageous, agility in the process, quality of products and services, certainty and last but not the least multi-task human resources are appeared to be core competencies of modern age organizations. Human Resource Management can be viewed as an approach to management that considers people as key resources. Human Resource Management is developed from the practice of Personnel Management. Personnel Management assists with the management of people in an organization. Personnel Management is concerned with establishing, maintaining and developing systems that provide the framework of employment. This framework of systems operates through employee’s relationship with the organization starting from recruitment to retirement (Eugene and Nic 2008). Personnel management is traditional and properly related to old model of organization, which is bureaucratic in nature. That means PM is less flexible and has higher degree of centralization. Personnel management is concerned with obtaining, developing and motivating human resources needed by the organization to achieve its objectives. The aim of personnel management is to make an effective contribution to the objectives of the organization and to the fulfillment of its social responsibilities (Armstrong, 2006). In addition, as Armstrong (2006) defines ‘Human Resource Management is a strategic and coherent approach to management of organizations’ most valued assets’. Human Resource Management system as HRM operates through HR system that brings together in a coherent way (Armstrong, 2006). HR philosophies: which describe the value and guiding principles adopted in managing people. HR Strategies defining the direction in which HRM intends to go HR Policies: these are the guidelines defining how these values, principles and strategies should be applied and implemented in specific areas of HRM. HR Processes: consisting of procedures and methods used to put HR strategic plans and policies into effect. HR Practices: comprising of informal approaches used to manage people. HR Programs: which enable HR strategies, policies and practices to be implemented according to plans. The role of HR manger has changed in response to social, economic, political conditions and to changes in technology and it is still developing dynamically. In addition, the relative importance of several activities has changed as external circumstances have affected the needs of organizations and it is still a dynamic area where the roles and ways of organizing the HR function continue to change and develop (Foot and Hook, 2008). the concept of Human Resource Management first appeared in the 1980s and the use of the term grew in the 1990s ( foot and Hook 2008). in HRM, there is a greater emphasis on strategic issues and on the way in which the human resource contributes to the achievement of corporate objectives. Write about SHRM There are ranges of activities that HR managers do on regular basis: recruitment and selection, learning and development, human resource planning, provision of contracts and fair treatment, provision of equal opportunities, managing diversity, motivating workers to achieve improved performance, employee counseling, talent management, payment and rewards, health and safety, dealing with grievances, redundancy, negotiation, adding value, ethics and corporate responsibility, change and knowledge management and so on (Foot and Hook, 2008).

Observe different person's behaviors in hospital Essay

Observe different person's behaviors in hospital - Essay Example From a theoretical point of view, the behavior shown at work is the result of operant conditioning reinforced through punishment and rewards. Therefore, individuals’ behavior can be assessed well only if they are approached from various dimensions. It is interesting to note that people who gather at a public place are more likely to express their real traits when compared to those at workplace. I spent some time observing how the patients and staff at Miami Children’s Hospital behave in the hospital premises. At the conference hall, I observe the parents or relatives of some patients attending Professor Juan Aqua’s orientation speech on ‘Childrens Medical Services Primary Care Program’ (CMS). He gives lectures on the significance of the program emphasizing on how the Miami Childrens Hospital Pediatric Care Center serves as a medical home for their child once enrolled in the Program. His old age and his low voice make it extremely difficult for audience to catch what he says. Evidently, he had this speech earlier perhaps for another batch, for he speaks to the audience as if they are already aware of the program. The staffs at the venue show no special interest in the speech as they are familiar with each and every aspect of the CMC. People attending the talk have multiple responses. Some are interested to hear what the professor says whereas those sitting in the last rows look distracted. Obviously, they are happy to get the professor to lecture from the middle of the class in a much louder voice. They may pay better attention to the professor’s lectures, and answer his questions only if the professor delivers lectures in a louder voice in an interactive way. Many of them remain unresponsive, waiting for their turn to move to the registration counter. The orientation program is mandatory for enrolment. However, there are a few parents who take notes of each

SMA Roles Assignment Example | Topics and Well Written Essays - 500 words

SMA Roles - Assignment Example While the tasks may be conducted in parallel, they are not independent. The conceptual model is a key means of validating the simulation model and addressing whether the right model is being built. Validation determines whether the model is a meaningful and accurate representation of the real system. The programmed model used for experimentation is a translation of the conceptual model into computer-executable form. Before experimentation, the programmed model must be verified to determine that it is working as intended. This step focuses on building the model right according to specifications. Conceptual modeling-Model formulation since it’s a conceptual representation of the system which captures the key elements in the system and their relationships and documents how the system works. Modeling involves characterizing input data as probability distributions. Models are developed through commercial simulation software packages available in the market place. The reasons for building models is to conduct analyses, increase understanding and obtain results. The role of a user in a simulation model is verification of the model. Since the model is developed to meet the user requirements, the user is responsible for verifying if the system meets his demands. Simulation modeling analysis involves identifying the purpose of the model, designing the model by studying the inputs and the expected outputs and translating the model into computer executable form which is then concluded by implementation of the model; putting the model into

Report Coursework Example | Topics and Well Written Essays - 1000 words - 7

Report - Coursework Example The purpose was to come up with a statistical explanation for their radioactivity and to establish the procedure. The coins were tossed and probability was used to determine the process of decay. The coins were put in a flat box with a cover and the box was shaken for a couple of seconds. After shaking, the coins were poured out onto a flat surface. The coins with their heads up were decayed. The coins with tails up were not decayed. Ten random tosses were made after shaking the box and the count of decayed coins was made after each toss. The decayed coins were then removed and the other coins returned into the box for more shake and spread on the table. According to the first hypothesis, the results show that the nine tosses from the box lead to decay of all coins. The line graph of experiment one shows that there is a gradual but approximately consistent decay of the 195 coins used. The second hypothesis according to the table is also averagely true. The results show that in four out of nine tosses, more than half of the coins decay. The cumulative frequency shows that all the 195 coins decay eventually. The coins were replaced with 16 new coins after every trial. The different sets of coins were put in the box and shaken then tossed on a table. The results were taken to determine the number of coins that decayed on the first throw. The coins should not be put in a box because collecting many boxes is tedious. They should be tossed only. One person should collect decayed coins, another tosses only. To avoid tampering with the decay substance. Time should also be calculated within tosses to ensure

The Marketing Mix and Key Stakeholder Groups for Ryanair Airline Assignment

The Marketing Mix and Key Stakeholder Groups for Ryanair Airline - Assignment Example This research will begin with the statement that in order to amplify the sustainability and reputation in this age of extreme aggressiveness, it is the stakeholders, who might present positive strategies and policies for the growth the organization. This is because, stakeholders are recognized as those individuals, in which the organization is entirely dependent over a long period of time. Moreover, varied types of internal motives and desires of these stakeholders get fulfilled due to the increase in the organizational productivity and profitability. Other than this, the stakeholders are those individuals, who get affected by the implementation of varied types of inventive activities by the organization. This section identifies the prime stakeholders of Ryanair Airline that offers significant impact and influence over organizational activities are employees, pressure groups, and shareholders. Employees: employees are considered as the internal stakeholders of an organization and pla y a very vital role in organizational improvement. This is because; it is the employees or the human resources of an organization that dedicates his or her total commitment so as to amplify his level of performance or goals. Similarly, the employees or human resources of Ryanair Airline might try to present effective attitude, behavior as well as services so as to satisfy the requirements of the customers. Only then, the reliability and trust of the customers over the hospitality of Ryanair Airlines might get enhanced that may improve the brand image and market share of the brand. Other than this, if the level of hospitality of the employees of Ryanair Airlines is extremely praise-worthy, then the range of customers might get increased that may amplify the profitability and productivity of the organization. However, in order to maintain such type of hospitality, the employees need to offer extensive training and development workshops so as to improve their communication skills and i ntelligence power. Apart from this, in order to make the employees as the most profitable assets of Ryanair, effective communication and participation system need to be implemented, at the time of developing any strategy or policy.

Case study Example | Topics and Well Written Essays - 500 words - 7

Case Study Example There is favoritism and discrimination going on at the workplace. An employee such as Fred, despite the fact that he is more skill oriented than Bob, and performs exceptionally well does not get an increase of his salary. There is the lack of privacy. Employees are not supposed to share their some information especially when it is salary oriented. Sharing this information could lead to a lot of conflicts in the workplace. As the director, I would carry out an evaluation process on each employee. I would do this by initiating a scale rating which usually indicates the strengths and weaknesses of every employee. The key areas I would concentrate on are, following rules and instructions, ability to get along with others and effectiveness. After carrying out the evaluation, I would call every employee and give feedback to them. If Fred seems to be working well, as he implies then I would recommend a raise of salary and promote him to a higher position. If he is under performing, I would have to release him off his duties. Jack Otto should introduce a policy of rewarding the exceptional employees, who keep time on arriving in the morning and employees who get along with other employees well. This would keep Bob on his toes and will even start arriving at the workplace earlier than expected. Putting up with Bob’s behavior for a long time, his lateness is not an issue anymore. The company has ignored Bob and actions have not been taken against him. This has spearheaded the existing problem with Bob. Policies usually provide ethics by which an institute governs its employee relations in a fair and steady manner. The policies and procedures help employees be aware of what is expected and can prevent misunderstandings about employer policies. Some of the policies which could have prevented the problem from happening are; George should establish a method for all employees in his department to report complains confidentially. He should also incorporate

Analytical Report Essay Example | Topics and Well Written Essays - 5500 words

Analytical Report - Essay Example Out of the total†¦Ã¢â‚¬ ¦..Academic semesters, †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ semesters are reserved for on-the job training in the form of Internship. I was admitted as an Intern in the Logistics firm â€Å" M/s Takhzeen Warehousing and Logistics company †TAKHZEEN† from†¦Ã¢â‚¬ ¦ to †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. The aim of my internship service is to familiarize me with the operations, management and impact of this logistics company, on the business of Logistics Service in the Arabian Gulf Region, the role it plays in this business, its management style and potentials for me to be a part of its growth, and thus achieve a career advancement for me. From my academic learning I know of the theoretical concepts underlying the business. I also realize that it is not always possible for a business to conform to typical theoretical models of work. Thus I would like to know how the company has molded its practices to get along with the ground realities. As a Trainee Manger, I am fascinated by the different tools available for upgrading Quality and service aspects of the business. I want to see how far the buzz words of Modern Quality Management, like ERP, TQM, Kaizen and Six Sigma are introduced in the Company, and also how far they have been successful in this Company. An ounce of practice is more valuable than a ton of theory. So I have used my Internship to closely watch the Organizational Setup, Command Chain, Supply Chain, Quality Management and Customer Management, as much as I study my academic specialty subject of Finance in the context of this company. Since I have the long term goal of owning and operating a Logistics company of my own, I would also be observing the company from the entrepreneur’s perspective. I would like to study the origin and growth of the Company over the years and see how best to adopt the lessons from its growth, to start and grow my own company. SECTION 2 1. Company Culture The Takhzeen Warehousing and & Storage Company† TAKHZEEN† was incorporated as a Closed Bahraini Shareholding Company. It has a strategic alliance with Al Muthana Investment Company of Kuwait and Al Khawari group of Saudi Arabia. The authorized Share Capital of the Company is $50 million, and the paid up capital is $10 million. The motivation for setting up of this company was the admiration and belief in the competence of the Saudi Arabian Company’s specialized knowledge and skill in the field of Logistics—cold storage, transport, and all allied aspects of logistics. Takhzeen looked forward to providing Professional and efficient Logistics support to the Private Sector in Bahrain and the Arabian Gulf region, benefiting from the expertise of its partners. For this, the Company expected to set the latest International standards and practices in its operations, with a view to set market standards in the region. Mr. Murad Al Ramadan, Managing Director of Takhzeen, and also Deputy C.E.O. for Investme nt set the short term goal of Takhzeen as identifying and entering the various opportunities in the area for Logistics service and expanding progressively into .the whole of the region. Another goal was to develop and provide training

Monetary policy responses by central banks during the early part of Essay

Monetary policy responses by central banks during the early part of the past decade aggravated the recent financial crisis - Essay Example The sub-prime mortgage market in particular was the target of these speculative flows which also made their way into the securities and equities markets as well. It can be said that the monetary policy of the Fed in the early years of the last decade encouraged excessive speculation in the United States economy (Mishkin, 2011, 23). However, to assign blame to the monetary policy of the Fed alone would be to exaggerate its role in the present global financial crisis as the issues of regulation and supervision of â€Å"exotic† financial products was one of the contributing factors as well. However, there is a consensual view which is increasingly being shared by many that at the heart of the reasons for the global imbalances lies the fact that the Fed kept interest rates â€Å"too low for too long† (Taylor,2008,14). This line of thought holds that by keeping the interest rates too low, the Fed encouraged the â€Å"real rate of return† in the US T-Bills or Treasurie s to increase leading to the rest of the world financing the yawning and steadily increasing current account deficit of the US. Further, the fact that these countries (led by Japan and China) were exporting huge amounts of goods and services gave them an incentive to â€Å"recycle† their dollar surpluses back into the US economy. Hence, it can be said that though the monetary policy of the Fed was aimed primarily at a domestic audience, due to the integrated and interconnected nature of the global economy indirectly contributed to the ongoing global financial crisis (BOE, 2010). It should be noted that the overly loose global monetary policy may have contributed to the weakening of the anchor on which â€Å"price stability† rested leading to excessive risk taking and by unleashing a global wave of euphoria contributed to the speculative tendencies in the financial sector. And this was a global phenomenon as well as central banks all over the world took their cue from t he Fed and pursued similar policies which had a cascading effect on the global economy in so far as the lethal combination of excessive liquidity and a lax regulatory structure combined to produce the global financial crises with which the world is even now struggling to cope with (Federal Reserve, 2010). References Blanchard, Dell’Ariccia, and Mauro, OB, G & P, 2010. Rethinking Macroeconomic Policy. IMF, Feb 2010, 1-18. ECB. (2010, April 9), â€Å"Could Monetary Policy have helped prevent the financial crisis?† Available from: http://www.ecb.int/press/key/date/2010/html/sp100409.en.html Mishkin, F, 2011. Monetary Policy Strategy: Lessons from the Crisis. National Bureau of Economic Research, Jan 2011, 1-65. Monetary Policy (2010), (Federal Reserve), Available: http://www.federalreserve.gov/monetarypolicy/default.htm (Accessed: 2011, Mar 14). News Releases (2011), (Federal Reserve), Available: http://www.federalreserve.gov/newsevents/default.htm (Accessed: 2011, Mar 14 ). News Releases (2011), (Bank of England), Available: http://www.bankofengland.co.uk/publications/news/2008/index.htm (Accessed: 2011, Mar 14). Taylor, JBT, 2008. The Financial Crisis and the Policy Responses: An Empirical Analysis of What Went Wrong. Stanford

Explain the European motivations for exploration and conquest of the New World Essay Example for Free

Explain the European motivations for exploration and conquest of the New World Essay The discovery of the New World happened to coincide with the spread of European power and culture around the known world. This spread was the result of various developments that had occurred, particularly the following: â€Å"the explosive growth of trade, towns, and modern corporations; the religious zeal generated by the Protestant Reformation and the Catholic Reformation;†1 as well as the usual reasons of â€Å"greed, conquest, racism, and slavery. †2 By the time of the 1400s, these and other forces combined to make Europeans search for new lands to conquer and settle, as well as for new people to convert, civilize, or exploit. 3 Columbus’ various voyages to the New World opened the door for more exploration and settlement of the New World. The first European power to make concerted efforts to explore the New World was Spain, and they had three distinct motives: to win over converts to Catholicism; to conquer land; and, to get rich. 4 Eventually following Spain were England and France, both of which had similar motives: to extend their empires into the New World, as well as profit from the establishment of colonies in the New World. Clearly, then, the ultimate goal of exploration and conquest in the New World was to increase power and wealth. 2. Explain the religious persecutions in England that pushed the Separatists into Plymouth and the Quakers into Pennsylvania. Explain how England’s Glorious Revolution also prompted changes in the colonies. The Separatists, also known as the Pilgrims, were forced out of England due to their religious beliefs. They were part of the â€Å"most uncompromising sect of Puritans†¦who had severed all ties with the Church of England. †5 They felt that the Church of England was not completely separated from the Catholic Church. Speaking out against the Church of England led to persecutions by King James I and Anglican officials. 6 The Separatists then fled to Holland, but while there, felt that their children were becoming too Dutch and straying from their staunch Puritan beliefs. As a result, they secured a land patent from the Virginia Company and in 1620, sailed to America. 7 The Quakers were the â€Å"most influential of many radical groups that sprang from†¦the English Civil War. †8 They carried further than any other group the doctrine of â€Å"individual spiritual inspiration and interpretation,† which they called â€Å"the inner light. †9 Doing away with many of the trappings of the Church of England, the Quakers embraced a simple way of life and were extremely pacifist. 10 This did not coincide with the ways of the Anglican Church, and thus, they were persecuted a great deal. They chose to leave England and settle in the New World, where they would be able to practice their beliefs without fear of reprisal. First establishing the colony of New Jersey, they soon migrated to the opposite side of the Delaware River and established the colony of Pennsylvania. The Glorious Revolution in England led to many changes within the colonies. The colonies that had been absorbed into the Dominion of New England – Massachusetts, Connecticut, Rhode Island, New York, and New Jersey – all reverted to their former governments. 11 They were also able to retain their former status, â€Å"except Massachusetts Bay and Plymouth, which†¦were united under a new charter in 1691 as the royal colony of Massachusetts Bay. †12 Another change was the passage of the Bill of Rights and the Toleration Act in England in 1689, both of which â€Å"limited the powers of the country’s monarchs and affirmed a degree of freedom of worship for all Christians, thereby influencing attitudes – and the course of events – in the colonies. †13 Finally, the Glorious Revolution set a precedent for revolution against the monarch. In other words, it laid the groundwork for the American Revolution, which would free the colonies from British rule. 14 5. Explain how and why the British won the French and Indian War. The French and Indian War was the last of four major wars involving the European powers and their New World colonies. 15 In this particular war, the cause of contention was upper Ohio River valley. Controlled by the French, they became irate when some Virginians moved into the territory to make trade with the Indians easier, as well as to survey land granted to them by King George III. 16 Attempts to warn off the French failed, and eventually warfare broke out in the disputed area. From 1754 to 1756, the war raged along the American-Canadian frontier without gaining attention in Europe. 17 From 1756 until the war ended, it would be merged with the Seven Years’ War in Europe. 18 The change in status of the French and Indian War coincided with a change within the British government. William Pitt became Prime Minister of Britain, and under his leadership, the British would defeat the French. Allied with the Indians, who wanted the French out of their territory, the British utilized their superior naval fleet to cut off French reinforcements and supplies to the New World. 19 The decisive point of the war was the Battle of Quebec in 1759. After two months of attempting to break French defenses, the British were able to find a path that allowed them to get closer to the French camp. In the battle that followed, the British routed the French, thus ending French power in North America. 20

Effects On Prisons On Inmates Essay Example for Free

Effects On Prisons On Inmates Essay In the premodern times, societies used to mutilate bodies and cut off the heads of their culprits as a way of punishing the wrongdoers. However through a series of imperceptible measures of reform and development, punishment became less physical and less directed to the body of the offenders as people became more civilized and the prisons replaced the gallows. They stopped locking up the insane in asylums and began forms of treatment in institutions which had features of both hospitals and prisons, (Alan Gary 4). In most parts of the world, it is taken that a person convicted of serious crime should be sent to prison. Countries like the U.S, where capital punishment has not yet been abolished, a small but significant number of people are sentenced to death for what is especially considered as grave crimes, (Angela 3). The condition of prisons in the past was a nightmare to both the country as well as the society as they were damp, dark, and noisy. Prison wardens were brutal, poor diet and miserable portions of food were given to prisoners who were usually dressed in rags and suffered from many diseases which were not treated in time resulting to poor heath of the inmates. All these inhuman acts were however viewed by the wardens as a way of punishment to prisoners and therefore the prisons lacked a sense of reformation and charity as brutal acts were directed to inmates. According to (Thomas 602), Inmates who entered prison capable of moral improvement went back in to the society as impure, hardened and irreclaimable persons as there was no separation of sexes, classification of age and character therefore the convicted felon corrupted the untried and innocent prisoners. The unfortunate According to (Douglas Eric 2004), military officers in Iraq used dogs to intimidate prisoners. This was one of the several tactics they adopted even without approval from their seniors. They set strict limits on Red Cross access to prisoners and delayed them and accused them of, unannounced visit to the cellblock where the worst abuses occurred. There were also unreported incidents in which Iraq prisoners died after being questioned by American interrogators. Initially, imprisonment was based on punishing wrongdoers by inflicting suffering of the body. However, today’s imprisonment is not only an acute form of corporal punishment, but as a way of working on a persons mind and body through three areas which include: punishment, deterrence and rehabilitation. Prisons are intended to allow the society remove criminals from them place them into an institution for reformation, persuade them to avoid activities which are not beneficial, and in time become productive and law abiding citizens. However this well thought plan is not put in place due to the bad experiences in prisons hence the initial meaning of prisons is not realized by the society.   The main objectives and responsibilities of prisons are to safeguard inmates and maintain and improve welfare of everyone in it. Safe guarding involves keeping inmates locked away and controlled while having moments of recreation, education and counseling. However, it should be realized that psychological freedom depends on relations with others and that it is what the prisoners experience in this world, attain satisfaction and avoid its detrimental effects and not the education or counseling that decide how, if ever, they will emerge hence life imprisonment of an inmate does not add to his becoming upright. It should therefore be remembered that offenders are drawn from societies where possessions are related to personal worth unlike in prison where they are reduced to a level of bare possessions. Lockups, isolation, condemnation and rejection dehumanize prisoners resulting to psychological discomforts to prisoners. A Prisons aim is to cure and straighten the bad behaviors of criminals, however their record has not been encouraging and instead they are found to do more harm than good as the pains of jail confinement affect all prisoners in different negative ways most of which destroy a person instead of reforming his or her past bad behavior. The need to quickly adapt to prison life and withstand prison shock, exposure to a new culture and maintain outside links like keeping in contact with family and friends becomes frustrating to prisoners. The prisoners must therefore determine their way of passing time which affects the great deal and this end up affecting them psychologically. (Tosh 43). All these question the practice of life imprisonment of people since instead of reforming them they end up becoming worse both in their behaviors and their psychological status. Prisons therefore should be opposed to the idea of locking up people for the rest of their lives to avoid more harm than good to them. (Alison 14-19), came up with several negative effects on prisoners as a result of imprisonment which therefore opposes the idea of life imprisonment. First is that imprisonment can be detrimental both to physical and mental health of prisoners particularly with regard to long term and aged prisoners. Though many prisoners receive medical treatment in prison that would be unavailable to them outside, the health risk of imprisonment are high, uneven and specific to the condition of confinement. For instance, Scottish prisons have reported increased risk of HIV and hepatitis B and C transmission due to random sharing of injection equipment, tattooing and unprotected sexual intercourse. One study estimates showed that 36% prisoners had injected themselves intravenously and 12% had anal intercourse at least once while in prison. Post- traumatic stress is second where its psychological effects apply to certain group of prisoners who have shown symptoms of PTSD in medico-legal assessments. Such symptoms can have debilitating effect and are associated with difficulties in restoring and maintaining relationships. High level of anxiety, disturbed sleep, chronic depression, withdrawal and persistent feeling of being different from others and from previous self are described by clinicians working with former prisoners. There may also be physical symptoms like increased arousal, outbursts of anger, difficulties in concentration and hyper vigilance which are associated with increased alcohol and drug abuse.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   (Davis 322) in the third effect argued that inmates’ family and dependants suffer most. Despite considerable progress in understanding immediate and long term effects of separation trauma upon children, the impact of imprisonment upon the children of prisoners includes increased behavior disturbance and later delinquency, depression and feeling of low self esteem, behavioral disturbance and deterioration in school performance. Imprisonment and distance from crime is another effect which results to informal social control which suggests that social bonds like employment and marriage may inhibit offending. The imprisonment reduces opportunities to achieve relational and economic stability and therefore increase re-offending. Imprisonment also weakens the bonds and makes them difficult to re-establish hence suffering a significant source of legitimate or law abiding behavior and therefore imprisonment becomes part of the cycle of delinquency and crime. Another effect is on imprisonment and prison staff. Power especially overuse has dehumanizing effect as the culture of masculinity characteristic of prison staff bring a range of emotions and new emotion management techniques. Some of these techniques can lead to hardening, distancing and distrust. The process of adaptation could lead to enduring changes in their character and family life to preparedness to respond to danger. Imprisonments also result to some prisoners using sexual assaults and rape to make them feel powerful. Many of them use this assault to make them feel powerful than others and also express their manhood. The victims as a result are affected psychologically by being stressed, having nightmares and resulting to criminal activities and some forms of self destructive behaviour. The main solution to all these problems is to avoid inmate staying for a very long time in prisons since they tend to be harder than before and that certainly does not cure inmates rather it makes them more aggressive. Others is by ensuring good living and health conditions for the inmates, counsel them on how to handle people and relationships within and outside the prisons especially their families, provide good counseling facilities on the negative effects of using sex as a tool to feel good and demoralize other inmates. In conclusion prisons and punishments that are given to the prisoners do not necessarily bring a positive change of behaviour.In most cases they end up destroying the person as he or she becomes immune to the situations, therefore putting a person in prison for the rest of his/her life does not ensure behavior change and should therefore opposed. WORK CITED Angela Yvonne Davis Are prisoners obsolete? Seven stories press ISBN 1583225811, 2003 Alan Hunt and Gary Wickman Sociological jurisprudence Pluto press ISBN 0745308422, 1994   Douglas Jehl and Eric Schmitt New York times 21st May 2004 Joanne Mariner and Michael Bochenek punishment before trial Human rights watch org ISBN 1564322017, 1997 Tosh John The pains of imprisonment sage publications California 1982