La Isabela, Columbuss First Colony in the Americas

La Isabela is the name of the first European town established in the Americas. La Isabela was settled by Christopher Columbus and 1,500 others in 1494 AD, on the northern coast of the island of Hispaniola, in what is now the Dominican Republic in the Caribbean Sea. La Isabela was the first European town, but it was not the first colony in the New World--that was LAnse aux Meadows, established by Norse colonists in Canada nearly 500 years earlier: both of these early colonies were abject failures. History of La Isabela In 1494, the Italian-born, Spanish-financed explorer Christopher Columbus was on his second voyage to the American continents, landing in Hispaniola with a group of 1,500 settlers. The primary purpose of the expedition was to establish a colony, a foothold in the Americas for Spain to begin its conquest. But Columbus was also there to discover sources of precious metals. There on the north shore of Hispaniola, they established the first European town in the New World, called La Isabela after Queen Isabella of Spain, who supported his voyage financially and politically. For an early colony, La Isabela was a fairly substantial settlement. The settlers quickly built several buildings, including a palace/citadel for Columbus to live in; a fortified storehouse (alhondiga) to store their material goods; several stone buildings for various purposes; and a European-style plaza. There is also evidence for several locations associated with silver and iron ore processing. Silver Ore Processing The silver processing operations at La Isabela involved the use of European galena, an ore of lead probably imported from ore fields in the Los Pedroches-Alcudia or Linares-La Carolina valleys of Spain. The purpose of the exportation of lead galena from Spain to the new colony is believed to have been to assay the percentage of gold and silver ore in artifacts stolen from the indigenous people of the New World. Later, it was used in a failed attempt to smelt iron ore. Artifacts associated with ore assay discovered at the site included 58 triangular graphite-tempered assaying crucibles, a kilogram (2.2 pounds) of liquid mercury, a concentration of about 90 kg (200 lbs) of galena, and several deposits of metallurgical slag, mostly concentrated near or within the fortified storehouse. Adjacent to the slag concentration was a small fire pit, believed to represent a furnace used to process the metal. Evidence for Scurvy Because historical records indicate that the colony was a failure, Tiesler and colleagues investigated the physical evidence of the conditions of the colonists, using macroscopic and histological (blood) evidence on the skeletons excavated from a contact-era cemetery. A total of 48 individuals were buried in La Isabelas church cemetery. Skeletal preservation was variable, and the researchers could only determine that at least 33 of the 48 were men and three were women. Children and adolescents were among the individuals, but there was no one older than 50 at the time of death. Among the 27 skeletons with adequate preservation, 20 exhibited lesions likely to have been caused by severe adult scurvy, a disease caused by a sustained lack of vitamin C and common to seafarers before the 18th century. Scurvy is reported to have caused 80% of all deaths during long sea voyages in the 16th and 17th centuries. Surviving reports of the colonists intense fatigue and physical exhaustion on and after arrival are clinical manifestations of scurvy. There were sources of vitamin C on Hispaniola, but the men  were not familiar enough with the local environment to pursue them, and instead relied on infrequent shipments from Spain to meet their dietary demands, shipments that did not include fruit. The Indigenous People At least two indigenous communities were located in the northwestern Dominican Republic where Columbus and his crew established La Isabela, known as the La Luperona and El Flaco archaeological sites. Both of these sites were occupied between the 3rd and 15th centuries, and have been the focus of archaeological investigations since 2013. The prehispanic people in the Caribbean region at the time of Columbuss landing were horticulturalists, who combined slash and burn land clearance and house gardens holding domesticated and managed plants with substantive hunting, fishing, and gathering. According to historic documents, the relationship was not a good one. Based on all the evidence, historical and archaeological, the La Isabela colony was a flat-out disaster: the colonists did not find any extensive quantities of ores, and hurricanes, crop failures, disease, mutinies, and conflicts with the resident Taà ­no made life unbearable. Columbus himself was recalled to Spain in 1496, to account for the financial disasters of the expedition, and the town was abandoned in 1498. Archaeology of La Isabela Archaeological investigations at La Isabela have been conducted since the late 1980s by a team led by Kathleen Deagan and Josà © M. Cruxent of the Florida Museum of Natural History, at which web site much more detail is available. Interestingly, like at the earlier Viking settlement of Lanse aux Meadows, evidence at La Isabela suggests that the European residents may have failed in part because they were unwilling to fully adapt to local living conditions. Sources Deagan K. 1996. Colonial transformation: Euro-American cultural genesis in the early Spanish-American colonies. Journal of Anthropological Research 52(2):135-160.Deagan K, and Cruxent JM. 2002. Columbuss Outpost Among the Tainos: Spain and America at La Isabela, 1493-1498. New Haven: Yale University Press.Deagan K, and Cruxent JM. 2002. Archaeology at La Isabela, America’s First European Town. New Haven: Yale University Press.Laffoon JE, Hoogland MLP, Davies GR, and Hofman CL. 2016. Human dietary assessment in the Pre-colonial Lesser Antilles: New stable isotope evidence from Lavoutte, Saint Lucia. Journal of Archaeological Science: Reports 5:168-180.Thibodeau AM, Killick DJ, Ruiz J, Chesley JT, Deagan K, Cruxent JM, and Lyman W. 2007. The strange case of the earliest silver extraction by European colonists in the New World. Proceedings of the National Academy of Sciences 104(9):3663-3666.Tiesler V, Coppa A, Zabala P, and Cucina A. 2016. Scurvy-related Morbidity and Death amon g Christopher Columbus Crew at La Isabela, the First European Town in the New World (1494–1498): An Assessment of the Skeletal and Historical Information. International Journal of Osteoarchaeology 26(2):191-202.Ting C, Neyt B, Ulloa Hung J, Hofman C, and Degryse P. 2016. The production of pre-Colonial ceramics in northwestern Hispaniola: A technological study of Meillacoid and Chicoid ceramics from La Luperona and El Flaco, Dominican Republic. Journal of Archaeological Science: Reports 6:376-385.VanderVeen JM. 2003. Review of Archaeology at La Isabela: Americas First European Town, and Columbuss Outpost among the Taino: Spain and America at La Isabela, 1494-1498. Latin American Antiquity 14(4):504-506.

Hamlet’s Hamlet Essay - 1989 Words

Hamlet’s Hamlet Shakespeare’s tragedy Hamlet highlights one character above all the others; it is Hamlet the protagonist, the hero, the good guy. This essay will be devoted to delineating his character in the play. The audience recognizes that Hamlet has a huge burden to carry for the entirety of the play, but few realize the full extent of this painful load. R.A. Foakes in â€Å"The Play’s Courtly Setting† explains: Perhaps the most terrible feature of his recognition of corruption everywhere is his recognition of it in himself too; where others deceive he must deceive too, where others act he must put on an antic disposition, where the inmost desires and passions of others must be revealed, so must his own†¦show more content†¦Louis B. Wright and Virginia A. LaMar in â€Å"Hamlet: A Man Who Thinks Before He Acts† explain the popularity of the protagonist as residing in the fact that modern man â€Å"must face crises in his own life that remind him of Hamlet’s dilemma. . . (62). Hamlet’s first soliloquy emphasizes the frailty of women – an obvious reference to his mother’s hasty and incestuous marriage to her husband’s brother: Frailty, thy name is woman!-- A little month, or ere those shoes were old With which she followd my poor fathers body, Like Niobe, all tears:--why she, even she-- O, God! a beast, that wants discourse of reason, Would have mournd longer--married with my uncle [. . .] . (1.2) Soon Horatio, the hero’s closest friend (â€Å"Horatio, thou art een as just a man / As eer my conversation coped withal.†), and Marcellus make contact with Hamlet and escort him to the ramparts of Elsinore. Philip Edwards in â€Å"The Ghost: Messenger from a Higher Court of Values?† explains that â€Å"Hamlet is galvanized into activity by the news of the appearance of a ghost that resembles his dead father†(Edwards 66-67). At one a.m. the Ghost reveals to the protagonist the extent of the evil within Elsinore. The Ghost says that King Hamlet I was murdered by Claudius, who had a relationship with Gertrude prior to the murder; the ghost requests revenge by Hamlet:Show MoreRelatedEssay on Hamlet’s Pride in Shakespeare’s Hamlet1459 Words   |  6 PagesWilliam Shakespeare’s tragic drama Hamlet, the hero, Hamlet, appears to be guilty of hubris, an overstepping of the bounds of both his and humanity’s destinies, which ultimately leads to his downfall. Reading the play with a consideration as to how Hamlet’s hubris manifests itself sheds light on why he performs certain actions, and simultaneously enlightens the reader to the dangers of attempting to overstep the confines of humanity. 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It is the intent of this essay to analyze and probe all the various aspects of this curious personality.    Ward and Trent in The Cambridge History of English and American Literature consider Shakespeare’s options in designing the character of Claudius:    There were at least two ways in which an ordinary, or rather more than ordinaryRead MoreThe Validity of Hamlets Insanity in William Shakespeares Hamlet828 Words   |  4 PagesThe Validity of Hamlets Insanity in William Shakespeares Hamlet One of the most asked questions concerning Hamlet, is whether or not during the play he was actually insane or merely acting. This issue is confusing because Hamlet states that he will act insane to exact revenge upon Claudius after he has met his fathers supposed ghost. However, there are many times during the play where it seems Hamlet could not possibly be acting. But while it is possible to be sane and act insane, by definition

Night World Secret Vampire Chapter 15 Free Essays

â€Å"Come on, it’s okay,† Thea said. She seemed to be aboutPoppy’s age, but she had a gentle, sensible air that gaveher authority. â€Å"Sit down. We will write a custom essay sample on Night World : Secret Vampire Chapter 15 or any similar topic only for you Order Now Here.† She set Poppy on ashabby couch and extended her wrist. Poppy stared atthe wrist for an instant and then remembered. James, giving her blood from his arm. Thatwashow to do it. Friendly andcivilized. She could see pale blue veins under the skin. And that sight blasted away the last of her hesitation. Instinct took over and she grabbed Thea’s arm. Thenext thing she knew she was drinking. Warm salty-sweetness. -Life. Relief from pain. It was so good that Poppy could almost cry. No wonder vampires hated humans, she thought dimly. Humansdidn’t have to hunt for this marvelous stuff; theywere full of it already. But, another part of her mind pointed out, Theawasn’t a human. She was a witch. Strange, becauseher blood tasted exactly the same. Poppy’s every sense confirmed it. So witches are just humans, but humans with special powers, Poppy thought. Interesting. It took an effort to control herself, to know whento stop. But she did stop. She let go of Thea’s wrist and sat back, a little embarrassed, licking her lips andteeth. She didn’t want to meet Thea’s brown eyes. It was only then that she realized she’d been keeping her thoughts shielded during the entire process.There had been no mental connection as there had been when she shared blood with James. So she’dmastered one vampire power already. Faster than James or Ash had expected. And she felt good now. Energetic enough to do theNetherlands skippy dance. Confident enough to smileat Thea. â€Å"Thank you,† she said. Thea smiled back, as if she found Poppy odd orquaint, but nice. She didn’t seem suspicious. â€Å"It’sokay,† she said, flexing her wrist and grimacinggently. For the first time Poppy was able to look aroundher. This room was more like a living room than partof a shop. Besides the couch there was a TV andseveral chairs. At the far end was a large table withcandles and incense burning. â€Å"This is the teaching room,† Thea said. â€Å"Grandmadoes spells here and lets the students hang out.† â€Å"And the other part is a store,† Poppy said, cautiously because she didn’t know what she was supposed to know. Thea didn’t look surprised. â€Å"Yes. I know you wouldn’t thinkthere’d be enough witches around here to keep us in business, but actually they come from all over the country. Grandma’s famous. Andher students buy a lot.† Poppy nodded, looking properly impressed. Shedidn’t dare ask more questions, but her chilly hearthad warmed just a tiny bit. All Night People weren’tharsh and evil. She had the feeling she could be friends with this girl if given the chance. Maybe she could make it in the Night World after all. â€Å"Well,thanksagain,† she murmured softly. â€Å"Don’t mention it. But don’t let Ash get you rundown like that, either. He’s soirresponsible.† â€Å"You wound me, Thea. You really do,† Ash said.He was standing in the doorway, holding the beadcurtain open with one hand. â€Å"But come to think ofit, I’m feeling a little run down myself†¦.† He raisedhis eyebrows insinuatingly. â€Å"Go jump in Lake Mead, Ash,† Thea said sweetly. Ash looked innocent and yearning. â€Å"Just a littlebite. A nibble. A nip,† he said. â€Å"You have such apretty white throat†¦.† â€Å"Who does?† Blaise said, pushing her way throughthe other half of the bead curtain. Poppy had the feeling she was only speaking to focus attention onherself. She stood in the center of the room andshook back her long black hair with the air of a girlused to attention. â€Å"You both do,† Ash said gallantly. Then he seemed to remember Poppy. â€Å"And, of course, this littledreamer has a pretty white everything.† Blaise, who had been smiling, now looked sour.She stared at Poppy long and hard. With dislikeand something else. Suspicion. Dawning suspicion. Poppy could feelit. Blaise’s thoughts were brightand sharp andmalicious,like jagged glass. Then suddenly Blaise smiled again. She looked atAsh. â€Å"I suppose you’ve come for the party,† she said.†No. What party?† Blaise sighed in a way that emphasized her lowcut blouse. â€Å"The Solstice party, of course. Thierry’sgiving a big one. Everybody willbe there.† Ash looked tempted. In the dim light of the teaching room his eyes gleamed dark. Then he shook hishead. â€Å"No, can’t make it. Sorry. I’m going to show Poppythe town.† â€Å"Well, you can do that and still come to the partylater. It won’t really get going until after midnight.†Blaise was staring at Ash with an odd insistence. Ashbit his lip, then shook his head again, smiling. â€Å"Well, maybe,† he said. â€Å"I’ll see how things go.† Poppy knew he was saying more than that. Someunspoken message seemed to be passing betweenhim and Blaise. But it wasn’t telepathic, and Poppy couldn’t pick it up. â€Å"Well, have a good time,† Thea said, and gavePoppy a quick smile as Ash piloted her away. Ash peered ahead at the Strip. â€Å"If we hurry wecan watch the volcano erupting,† he said. Poppy gavehim a look, but didn’t ask. Instead, she said, â€Å"What’s a Solstice party?† â€Å"Summer solstice. The longest day of the year. It’sa holiday for the Night People. Like Groundhog Dayfor humans.† ?Why?† â€Å"Oh, it always has been. It’s very magical, youknow. I’d take you to the party, but it would be toodangerous. Thierry’s a vampire Elder.† Then he said, â€Å"Here’s the volcano.† It was a volcano. In front of a hotel. Waterfallscrashed down its sides, and red lights shone from thecone. Ash double-parked across the street. â€Å"You see, we’ve got a great view right here,† hesaid. â€Å"All the comforts of home.† The volcano was emitting rumbling sounds. AsPoppy watched in disbelief, a pillar of fire shot outof the top. Real fire. Then the waterfalls caught fire.Red and gold flames spread down the sides of the black rock until the entire lake around the’ volcanowas ablaze. â€Å"Inspiring, isn’t it?† Ash asked, very close to herear. â€Å"Well-it’s†¦Ã¢â‚¬  â€Å"Thrilling?† Ash inquired. â€Å"Stimulating? Rousing?† His arm was creeping around her, and his voicewas sweetly hypnotic. Poppy didn’t say anything. â€Å"You know,† Ash murmured, â€Å"you can see a lotbetter if you get over here. I don’t mind crowding.† His arm was urging her gently but inevitably closer. His breath ruffled her hair. Poppy slammed an elbow into his stomach. â€Å"Hey!†Ash yelped-in genuine pain, Poppy thought. Good. He’d dropped his arm and now he was looking ather with aggrieved brown eyes. â€Å"What did you do that for?† â€Å"Because I feltlike it,† Poppy said smartly. She was tingling with new blood and ready for a fight. â€Å"Look,Ash, I don’t know what gave you the idea that I’m your date here. But I’m telling you right now thatI’m not. â€Å" Ash tilted his head and smiledpainfully.†You justdon’t know me well enough,† he offered. â€Å"When weget to know each other-â€Å" â€Å"No.Never. I’m not interested in other guys. If Ican’t have James †¦Ã¢â‚¬ Poppy had to stop and steady her voice. â€Å"There’s nobody else I want,† she saidfinally,flatly. â€Å"Nobody.† â€Å"Well, not now, maybe, but-â€Å" â€Å"Never.†She didn’t know how to explain. Thenshe had an idea. â€Å"You know the soulmate principle?† Ash opened his mouth and then shut it. Openedit again. â€Å"Oh, no. Not thatgarbage.† â€Å"Yes. James is my soulmate. I’m sorry if it soundsstupid, but it’s true.† Ash put a hand to his forehead. Then he started to laugh. â€Å"You’re serious.† â€Å"Yes.† â€Å"And that’s your final word.† â€Å"Yes.† Ash laughed again, sighed, and cast his eyes upward. â€Å"Okay. Okay. I should have known.† He chuckled in what seemed like self-derision. Poppy was relieved. She’d been afraid he’d be disgruntled and huffy-or mean.Despite his charm, shecould always feel something cold running below thesurface in Ash, like an icy river. But now he seemed perfectly good-humored.†Okay,† he said. â€Å"So if romance isn’t on the menu, let’s go to the party.† â€Å"I thought you said it was too dangerous.† He waved a hand. â€Å"That was a little fib. To get youalone, you know.† He glanced sideways at her.†Sorry.† Poppy hesitated. She didn’t care about a party. Butshe didn’t want to be alone with Ash, either. â€Å"Maybe you should just take me back to your cousins’ place.† â€Å"They won’t bethere,† Ash said. â€Å"I’m sure they’ve gone to the party by now. Oh, come on, it’ll be fun. Give me a chance to make things up to you.† Thin curls of uneasiness were roiling inside Poppy. But Ash looked so penitent and persuasive †¦andwhat other choice did she have? â€Å"Okay,† she said finally. â€Å"For just a little while.†Ash gave a dazzling smile. â€Å"Just a very littlewhile,† he said. â€Å"So they could be anywhere on the Strip,†James said. Thea sighed. â€Å"I’m sorry. I should have known Ashwas up to something. But hijacking your girlfriend†¦Ã¢â‚¬ She lifted her hands in a what-next gesture. â€Å"Forwhat it’s worth, she didn’t seem very interested inhim. If he’s planning to put the moves on her, he’sgoing to get a surprise.† Yes, James thought, and so is she. Poppy was onlyuseful to Ash as long as Ash thought he could playwith her. Once he realized he couldn’t†¦ He didn’t want to think about what would happenthen. A quick visit to the nearest Elder, he supposed. His heart was pounding, and there was a ringingin his ears. â€Å"Did Blaise go with them?† he asked. â€Å"No, she went to the Solstice party. She tried to get Ash to go, but he said he wanted to show Poppythe town.† Thea paused, raising a finger. â€Å"Waityou might check at the party. Ash said he might stopin later.† James spent a moment forcing himself to breathe.Then he said, verygently, â€Å"And just who is giving this party?† â€Å"Thierry Descouedres. He always has a big one.†Ã¢â‚¬ And he’s an Elder.† â€Å"What?† â€Å"Nothing. Never mind.† James backed out of theshop. â€Å"Thanks for the help. I’ll be in touch.†Ã¢â‚¬ James†¦Ã¢â‚¬ She looked at him helplessly. â€Å"Do youwant to come in and sit down? You don’t lookvery well†¦.† â€Å"I’m fine,† James said, already out the door.In the car he said, â€Å"You can get up now.† Phillip emerged from the floor of the backseatwhere he’d been hiding. â€Å"What’s happening? Youwere gone a long time.† â€Å"I think I know where Poppy is.†Ã¢â‚¬ You just think?† â€Å"Shut up, Phil.† He didn’t have energy for exchanging insults. He was entirely focused on Poppy.†Okay, so where is she?† James spoke precisely. â€Å"She is either now, or shewilll be later, at a party. A very large party, filled with vampires. And at least one Elder. The perfect placeto expose her.† Phil gulped. â€Å"And you think that’s what Ash is going to do?† â€Å"I know that’s what Ash is going to do.† â€Å"Then we’ve got to stop him.† â€Å"We may be too late.† The party was strange. Poppy was amazed at howyoung most of the people were. There were a few scattered adults, but far more teenagers. â€Å"Made vampires,† Ash explained obligingly. Poppyremembered what James had said-made vampiresremained forever the age of their death, but lamiacould stop aging anytime. She supposed that meantthat James could get as old as he wanted, while she would be stuck at sixteen eternally. Not that it mattered. If she and James were going to be together,they could both stay young-but apart, maybe he’d want to age. But it was odd to see a guy who looked about nineteen talking earnestly with a little kid wholooked about four. The kid was cute, with shiny black hair and tilted eyes, but there was something at onceinnocent and cruel in his expression. â€Å"Let’s see, now that’s Circe. A witch of renown.And that’s Sekhmet, a shapeshifter. You don’t want to get hermad,† Ash said genially.He and Poppy were standing in a little anteroom, looking down a level into the main room of the house. Of the mansion, rather. It was the most opulent private residence Poppy had ever seen–and she’d seen Bel Airand BeverlyHills. â€Å"Okay,† Poppy said, looking in the general?direc tion he was pointing. She saw two tall and lovelygirls, but she had no idea which was which. â€Å"And that’s Thierry, our host. He’s an Elder.† An Elder? The guy Ash was indicating didn’t seemolder than nineteen. He was beautiful, like all thevampires, tall and blond and pensive. Almost sadlooking. â€Å"How old ishe?† â€Å"Oh, I forget. He got bitten by an ancestress ofmine a long time ago. Back when people lived incaves.† Poppy thought he was joking. But maybe not. â€Å"What do the Elders do, exactly?† â€Å"They just make rules. And see that people keepthem.† An odd smile was playing around Ash’s lips. He turned to look directly at Poppy. With the black eyes of a snake.That was when Poppy knew. She backed away rapidly. But Ash came after her,just as rapidly. She saw a door on the other side of the anteroom and headed for it. Got through it. Onlyto find herself on a balcony. With her eyes, she measured the distance to the ground. But before she could make another move, Ash had her arm. Don’t fight yet, her mind counseled desperately. He’s strong. Wait for an opportunity. She made herself relax a fraction and met Ash’s dark gaze. â€Å"You brought me here.† â€Å"Yes.† â€Å"To hand me over.†He smiled.†But why?† Ash threw back his head and laughed. It waslovely, melodious laughter, and it made Poppy sick. â€Å"You’re a human,† he said. â€Å"Or you should be. James should never have done what he did.†Poppy’s heart was racing, but her mind was oddlyclear. Maybe she’d known all along that this was what he was going to do. Maybe it was even the rightthing to do. If she couldn’t be with James and she couldn’t be with her family, did the rest really matter? Did she wantto live in the Night World if it wasfull of people like Blaise and Ash? â€Å"So you don’t care about James, either,† she said.†You’re willing to put him in danger to get rid of me.† Ash considered, then grinned. â€Å"James can takecare of himself,† he said. Which was obviously Ash’s entire philosophy. Everybody took care of themselves, and nobody helpedanybody else. â€Å"And Blaise knew, too,† Poppy said. â€Å"She knew what you were going to do and she didn’t care.† â€Å"Not much gets past Blaise,† Ash said. He startedto say something else-and Poppy saw her chance. She kicked-hard. And twisted at the same time.Trying to get over the balcony rail. â€Å"Stay here,† James said to Phil before the car had evenstopped. They were in front of a huge white mansionfringed with palm trees. James threw the door open,but took the time to say again, â€Å"Stay here.No matter what happens, don’t go in that house. And if somebodybesides me comes up to the car, drive away.† â€Å"But-â€Å" â€Å"Just do it, Phil! Unless you want to find out aboutdeath firsthand-tonight.† James set out at a dead run for the mansion. Hewas too intent to really notice the sound of a cardoor opening behind him. â€Å"And you looked like such a nice girl,† Ash gasped.He had both of Poppy’s arms behind her back andwas trying to get out of the range of her feet.†No-no, quit that, now.† He was too strong. There was nothing Poppy coulddo. Inch by inch he was dragging her back into theanteroom. You might as well give up, Poppy’s mind told her.It’s useless. You’re done. She could picture the whole thing: herself being dragged out in front of all of those sleek and handsome Night People and revealed. She could picturetheir pitiless eyes. That pensive-looking guy wouldwalk up to her and his face would change and hewouldn’t look pensive anymore. He’d look savage.His teeth would grow. His eyes would go silvery.Then he’d snarl–and strike. And that would be the end of Poppy. Maybe that wasn’t the way they did it, maybe theyexecuted criminals some other way in the NightWorld. But it wouldn’t be pleasant, whatever it was. And I won’t makeiteasyfor you!Poppy thought. Shethought it directly at Ash, throwing all of her angerand grief and betrayal at him. Instinctively. Like akid shouting in a temper tantrum. Except it had an effect shouting usually didn’t. Ash flinched. He almost lost his grip on her arms. It was only a momentary weakening, but it wasenough for Poppy’s eyes to widen. I hurt him. Ihurthim! She stopped struggling physically in that same instant. She put all her concentration, all her energy,into a mental explosion. A thought-bomb. LET GO OF ME YOU ROTTEN VAMPIRE CREEP! Ash staggered. Poppy did it again, this time makingher thought a fire hose, a high-power jetstreambombardment. LET G000000000000! Ash let go. Then, as Poppy ran out of steam, hetried in afumblingway to reach her again. â€Å"I don’t think so,† a voice as cold as steel said.Poppy looked into the anteroom and saw James. Her heart lurched violently. And then, withoutconsciously being aware of moving, she was in hisarms. Oh, James, how did youfind me? All he kept saying was Are you all right? â€Å"Yes,† Poppy said finally, aloud. It was indescribably good to be with him again, to be held by him.Like waking up from a nightmare to see your mothersmiling. She buried her face in his neck. â€Å"You’re sure you’re all right?† â€Å"Yes. Yes.† â€Å"Good. Then just hang on a moment while I kill this guy and we’ll go.† He was absolutely serious. Poppy could feel it in his thoughts, in every muscle and sinew of his body.He wanted to murder Ash. She lifted her head at the sound of Ash’s laugh.†Well, it ought to be a good fight, anyway,† Ashsaid. No, Poppy thought. Ash was looking silky and dangerous and in a very bad mood. And even if James could beat him, James was going to get hurt. Evenif she and James fought him together, there was going to be some damage. â€Å"Let’s just go,† she said to James. â€Å"Quick.† Sheadded silently, Ithink he wants to keep us around untilsomebody from the party gets here. â€Å"No, no,† Ash said, in gloatingly enthusiastic tones.†Let’s settle this like vampires.† â€Å"Let’s not,† said a breathless familiar voice. Poppy’shead jerked around. Climbing over the railing of thebalcony, dusty but triumphant, was Phil. â€Å"Don’t you everlisten?† James said to him. â€Å"Well, well,† Ash said. â€Å"A human in an Elder’shouse. What arewe going to do about that?† â€Å"Look, buddy,† Phil said, still breathless, brushingoff his hands. â€Å"I don’t know who you are or whathorse you rode in on. But that’s my sisterthere you’re messing with, and I figure I’ve got the first right to knock your head off.† There was a pause while Poppy, James, and Ash all looked at him. The pause stretched. Poppy wasaware of a sudden, completely inappropriate impulse to laugh. Then she realized that James was fightingdesperately not to crack a smile. Ash just looked Phil up and down, then looked atJames sideways. â€Å"Does this guyunderstandabout vampires?† hesaid. â€Å"Oh, yeah,† James said blandly. â€Å"And he’s going to knock my head in?† â€Å"Yeah,† Phil said, and cracked his knuckles. â€Å"What’s so surprising about that?† There was another pause.Poppycould feel minute tremors going through James. Choked-back laughter.At last James said, admirably sober, â€Å"Philreally feelsstrongly about his sister.† Ash looked at Philonce more, then at James, andfinally at Poppy. â€Å"Well †¦ there are three of you,† he said. â€Å"Yes, there are,† James said, genuinely sober now. Grim. â€Å"So I guess you do have me at a disadvantage. Allright,I giveup.† He lifted his hands and thendropped them. â€Å"Go on, scram. I won’t fight.† â€Å"And you won’t tell on us, either,† James said. Itwasn’t a request. â€Å"I wasn’t going to anyway,† Ash said. He had onhis most innocent and guileless expression. â€Å"I knowyou think I brought Poppy here to expose her, but I really wasn’t going to go through with it. I was justhaving fun. The whole thing was just a joke.† â€Å"Oh, sure,† Phil said. â€Å"Don’t even bother lying,† James said. But Poppy, oddly, wasn’t as certain as they were.She looked at Ash’s wide eyes-his wide violeteyes-and felt doubt slosh back and forth inside her. It was hard to read him, as it had been hard allalong. Maybe because he always meant everythinghe said at the time he said it–or maybe because he nevermeant anything he said. No matter which,, he was the most irritating, frustrating, impossible personshe’d ever met. â€Å"Okay, we’re going now,† James said. â€Å"We’re goingto walk very quietly and calmly right through that littleroom and down the hall, and we’re not going to stopfor anything-Phillip.Unless you’d rather go back downthe way you came up,† he added. Phil shook his head. James gathered Poppy in hisarm again, but he paused and looked back at Ash. â€Å"You know, you’ve never really cared about anyone,† he said. â€Å"But someday you will, and it’s goingto hurt. It’s going to hurt-a lot.† Ash looked back at him, and Poppy could readnothing in his ever-changing eyes. But just as Jamesturned again, he said, â€Å"I think you’re a lousyprophet. But your girlfriend’s a good one. You mightwant to ask her about her dreams sometime.† James stopped. He frowned. â€Å"What?† â€Å"And you, little dreamer, you might want to check out your family tree. You have a very loud yell.† He smiled at Poppy engagingly. â€Å"Bye now.† James stayed for another minute or so, just staringat his cousin. Ash gazed serenely back. Poppycounted heartbeats while the two of them stoodmotionless. Then James shook himself slightly and turnedPoppy toward the anteroom. Phil followed right on their heels. They walked out of the house very quietly andvery calmly. No one tried to stop them. But Poppy didn’t feel safe until they were on theroad. â€Å"What did he mean with that crack about the family tree?† Phil asked from the backseat. James gave him an odd look, but answered with aquestion. â€Å"Phil, how did you know where to findPoppy in that house? Did you see her on the balcony?† â€Å"No, I just followed the shouting.† Poppy turned around to look at him.James said, â€Å"What shouting?† â€Å"Theshouting. Poppy shouting. ‘Let go of me yourotten vampire creep.†Ã¢â‚¬Ëœ Poppy turned to James. â€Å"Should hehave been ableto hear it? I thought I was just yelling at Ash. Dideverybody at the party hear?† â€Å"No.† â€Å"But, then–â€Å" James cut her off. â€Å"What dream was Ash talkingabout?† â€Å"Just a dream I had,† Poppy said, bewildered. â€Å"Idreamed about him before I actually met him.† James’s expression was now verypeculiar. â€Å"Oh,did you?† â€Å"Yes. James, what’s this all about? What did hemean, I should check my family tree?† â€Å"He meant that you-and Philaren’t human after all. Somewhere among your ancestors there’sa witch.† How to cite Night World : Secret Vampire Chapter 15, Essay examples

Sexual Harassment in Employment Law

Question: Discuss about the Sexual Harassment in Employment Law. Answer: Introduction: In this paper we conduct a comparative and contrast research on the topic of Employers Liability for Sexual Harassment at Workplace. Sexual harassment is a discrimination which is based on sex. When a person is harassed sexually at his workplace, then this would be consider an attack on the personal dignity of the person. Such harassment not only affects the dignity of the person but also affects the effectiveness of their working, and restricts their earning potential. Practices related to sexual harassment not only affects the victim only but it also affects other employees of the company, and disturbs the environment at workplace. Sexual harassment at workplace can be defined as any unwanted behavior which is sexual in nature, and such behavior occurs at the workplace (OHRC, n.d.). Usually, victims of sexual harassment at workplace are women. It must be noted that they are not the only victims. Men can also be the victim of sexual harassment at workplace, but chances of harassment of men are less. Sexual harassment at workplace is experienced by almost 90% Canadian womens, and they admit that they faced such incident once in their lives. In case of men almost 90% mens admit that they witnessed such incident during their working lives. This paper contains the discussion related to liability of employer for those actions of its employees which are outside the scope of employment. We consider and evaluate the divergent point of view on the abovementioned topic. In last we conclude the essay by presenting our view on different concepts of this topic. Sexual harassment at workplace: Before discussing the employers liability it is necessary that we understand the meaning and concept of sexual harassment. Sexual harassment at workplace is the big problem for the Canadian workforce and victim feel afraid and powerless because of which they did not file complaint against such acts. Supreme Court of Canada defines the meaning of sexual harassment at workplace in such manner that any conduct which is sexual in nature and not welcomed by the victim is considered as sexual harassment. Such conduct not only affects the personal and human dignity of the victim but also affect the work environment at work place. Such behavior results in consequences related to earnings and job of the victim. Sexual harassment is another form of sex discrimination (Canadian Labor Relations, n.d.). In Canada sexual harassment is divided in two types that are: Quid Pro Quo sexual harassment: Quid Pro Quo is Latin version of this for that. In the context of workplace it means a favor for a favor. We can understand this with the help of the example, if any supervisor or any other senior authority offers promotion in work to its subordinate or junior employee, if such employee or junior submit his/her employee unwelcome employee behavior. Hostile work environment sexual harassment: this type of sexual harassment is very common at workplace. It includes series of incidents which involves hostility and unwelcome sexual behavior. However we can say that a single incident is sufficient to create environment which is hostile at workplace. For example unwanted verbal, gestures that are sexual in nature (Canadian Labor Relations, n.d.). Canadians has right to file both criminal case against the assailant and can claim for compensation from their employer or from assailant employer in case of sexual harassment at workplace. Employers are financially liable if there is any incident of sexual assault happens at their workplace. This liability of compensation occurred on employer under constructive dismissal labor law claims. In Canada people are aware that they can claim for financial compensation against their employer in case of leaving their job early because of sexual assault, but they are not aware that they can also file civil claim against their employer as well. Victim can file civil claim in case when employer is found vicariously liable for the sexual assault committed by his employee (Sex assault.Ca, n.d.). Vicarious liability means, it is the liability of the employer that he pay compensation in financial terms to the victim. Such liability on employer is important, because in many cases assailant does not have enough financial resources so that he pays to the victim or judgment. Vicarious liability of employer based on the circumstances of the case, and such factors include: Policies framed by employer related to safety and sexual assault. Awareness of employer in the matters related to sexual assault. Circumstances in which assailant establish contact with the victim Exact place where incident of sexual harassment occurred. It is the general rule that employer is liable for the acts done by its employees, and in case of sexual harassment also employer is financially liable for the act of employee whether or not this offence is committed with the person who is fellow employee. In case when victim is fellow employee, then in such case employer is liable to pay both law suit related damages and constructive dismissal termination benefits. In case, when assailant is working under the employer or if any connection is found between the job, victim and sexual assault then victim is cannot seek constructive dismissal termination benefits from the employer of assailant, but victim can seek law suit related damages from the employer of assailant (Viviers, 2016, Christiansen, n.d.). Canada Labour Code states that every employee in Canada has right to work in the environment which is free from sexual harassment. We have already mentioned above that employer is liable for the acts of its employees, and it is clear that it is the duty of the employer that he takes reasonable steps to prevent sexual harassment at workplace. It is necessary that every employer must make some policies after consulting with its employees to deal with the matters of sexual harassment (Government of Canada, n.d.). Law related to sexual harassment in Canada: Canada Labour Code states the rights of the employees to work in environment which is free from sexual harassment, and requires that employer has to take actions to prevent such matters. Canada Labour Code defines the sexual harassment, and according to this Code any conduct, comment, gesture or contact which is sexual in nature cause or likely to cause any humiliation or offence that can be understand on reasonable grounds that person puts condition of a sexual nature on employment, training or promotion. It is necessary that employers introduce the policy related to sexual harassment at workplace (Government of Canada, n.d.). Canada Labour Code state that every employee has right to work in environment which is free from sexual harassment. Canada Labour Code defines that employer must take reasonable steps to ensure that no employee is subject to sexual harassment. Canada Labour Code defines that employer must make some policy to prevent the activities of sexual harassment, and clause 2 of this section defines the contents of the policy which was specified in clause (1) of this section. Following are the contents of policies that employer has made to prevent the sexual harassment at workplace: Policy page must contain the definition of sexual harassment which is specified in the code. Policy paper must contain the statement that every employee has right to work in the environment which is free from sexual harassment. Policy paper contain that employer will take all reasonable efforts to ensure that every employee must work in sexual harassment free environment. Statement that in matter of sexual harassment employer will take reasonable actions against the assailant. Statement which state the procedure to file the complaint against the sexual harassment to the employer. Policy paper contain the statement that employer maintain the confidentiality in this matter, and does not disclose the name of the person who lodge complain against the sexual harassment. It must be noted that employer can disclose the information and name of the person when such disclosure is necessary for the purpose of investigation. Policy paper contains the statement which states the rights of the employees to file complaint under the Canadian Human Rights Act Clause (3) of this section states that it is the duty of the employer that each person in the organization must aware about the policy specified in clause (1) of this section (Canada Labour Code, n.d.). Any person who has recognized by the Federal Law in Canada as an employer must develop a policy that deals with the sexual harassment and employer develop that policy after consulting its employees or with any union which was representing the employees of the company. Courts in Canada impose the liability on employer for the sexual harassment conducted by its employee with fellow employees, customer, client or any other person if such harassment is conducted at the workplace or that incident has any connection with the job of the employee. The Canadian Human Rights Commission summarizes the standard established by court in Canada for the cases related to sexual harassment at workplace. Following is the summary of standard established by Canadian court: Employers are liable for the acts of its employees related to harassment at workplace. Supreme Court of the Canada stated that it is the aim of the human rights law to identify the discrimination, and then eliminate that discrimination. Court further stated that employers are the persons who have the control of the organization, and they are the only people who can reverse the negative impacts of sexual harassment and ensure healthy environment to work for its employees. Therefore, that does not matter what kind of business or workplace it was, employer is responsible to make sure that any employee does not face the problems related to sexual harassment. If harassment occurs then it is the duty of employer to show that he takes all reasonable steps to prevent the harassment (UN Women, n.d.). Parliament of Canada introduced the Canadian Human Rights Act to fight against the discrimination. The intention of parliament behind this was to provide equal treatment and opportunity to everyone in Canada. The main aim of this act was to promote equality in Canada. This commission receives many complaints, and these complaints are settled through meditation or resolved through the process of dispute resolution. In some cases these complaints are referred to Canadian Human Rights Tribunal for adjudication (Canadian Human Rights Commission, 2012). Section 7(1) and (2) of the Ontario Human Rights Code (OHRC) defines the rights of the person to free from harassment related to sex and any other comment which was related to gender at workplace or housing. Section 7(1) states that any person who occupy an accommodation has right to enjoy his accommodation free from harassment related to sex, sexual orientation, gender identity or gender expression by the landlord, agent or any other occupier lives in the same accommodation. Section 7(2) states that any person who is employee of any organization has right to work at place that is free from harassment related to sex, sexual orientation, gender identity or gender expression by the employer, agent or any other employee. Section 7(3) prohibits sexual solicitation by a person who is in a position that he can confer benefit. Section states that every person has right to free from the sexual solicitation by the person who is in a position to confer, grant or deny a benefit to the person if such person making the solicitation knows that it is unwelcome by other person (OHRC, n.d., OHRC, n.d.). Different views regarding this issue: An above stated facts shows that employers are liable for the actions of their employees that are out of the employment contract such as sexual harassment at work place. Peoples have different views regarding the employers liability for the acts of their employees, and whether employer is liable or not for the acts of employees is depend on the circumstances and facts of the case. There are different views regarding this issue which has their own logic, and own facts. In some cases it is justified that employers has vicarious liability for the acts of its employees, but in some cases it seems unjustified to held the employer liable for the acts of its employees which are done out of the employment. In this paper we discuss the question and views whether employer should be held liable or not for the acts of its employees? Prevention is the most effective strategy to stop sexual harassment. It is not possible that harassment reduced by its own, therefore law impose responsibility to prevent sexual harassment on the employer. In Canada employers are responsible to provide healthy work environment to its employees which is free from sexual harassment or does not discriminate between any employees. Law also levy burden on employer to take steps to prevent sexual harassment at workplace. In case if employer does not take reasonable steps to prevent the harassment at workplace then he is liable for the sexual harassment that has occurred at workplace, even if he does not know about the sexual harassment (HRliabrary, n.d.). It is already stated above that vicarious liability is imposed on employer for the acts of employees, but it is necessary to understand that up to what extent employer should be held liable, and standard of liability. First, it is necessary to state that who can be held liable for the sexual harassment at work place assailant, employer or both. Liability for sexual harassment is attached directly to the assailant or vicariously to the employer. It might be possible that court does not impose any liability on employer for the acts of the employees. Second, in case if court held the employer liable for the act of its employees, then up to what extent standards of vicarious liability applied on employer. Usually, employer of the company held liable for the acts of the employees automatically whenever the sexual harassment occurs. There are possibilities that employer is held liable only when he does not take reasonable steps to prevent the sexual harassment at workplace. Third, court must specify if employer is held liable then how liability would occur on employer, and how it would be apportioned between assailant and employer such as it might be levied jointly on both or severally (Smith, n.d.). As OHRC in Canada, has specified that employers are directly responsible to keep their workplace free from discrimination and harassment. It is the duty of the employer that he provides workplace where human rights are respected and employees treated equally and get equal opportunities. Employers violate the provisions of this code when they directly or indirectly violate this code, intentionally or unintentionally violate this code, constructively discriminate, and directly did not infringe the code but ratify such behavior or action which violates the code. When any employee infringe this code in the course of his employment, then in such case employer will be held liable for the acts of its employee. Section 46.3 of the code applied in case of discrimination, not in the case of harassment. Under the provisions of vicarious liability employer is liable for the acts of its employees even he did not know about such act (OHRC, n.d.). In Canada, employer is held liable for the acts of its employees even in case when they are unaware about the act of its employee. Another view related to this legal issue is whether it is right or not to held employer liable for the acts of employees, if employer takes all the reasonable steps to prevent sexual harassment at workplace, and also he is unaware about the act of employee (Berta, 2003). Before going further in this discussion it is important to know in which situations employer is held liable, in following circumstances court held employer liable: When employer does not frame or enforce policy related to workplace harassment. When employer does not conduct any training or education program me related to identification and elimination of harassment at workplace. When employer does not handle or investigate the complaints properly. When employer willfully ignore the acts of harassment at workplace (BH, n.d.). It must be noted that employer should not be held liable in case he proves that he take reasonable care and steps to prevent sexual harassment at workplace, and he proves that he take such steps to prevent sexual harassment. We can understand this with the help of the case law Robichaud v. Canada (Treasury Board). in this case supreme court of Canada held that employer is liable for the acts of its employees in course of their employment. The appeal was filed by Bonnie Robichaud and by the Canadian Human Rights Commission against the decision of the Federal Court of Appeal. Federal Court of Appeal held that Mrs. Bonnie Robichaud was sexually harassed by her supervisor, and employed by the Department of National Defence. In this case Department of National Defence is not liable for the contravention of her rights. Court further held that aim of human rights legislation is to eliminate discrimination. The legislation does not focus on finding the faults, but focus on providing remedies. The Canadian human right act is misunderstood and wrongly interpretate by some people that employers are not liable for the acts of harassment by its employees. This act considered the effects of discrimination and not the causes of the discrimination, and act recognized many remedies which employer can provide to the victim. Only employer can give environment at workplace which is free from harassment, compensation for the loss of wages, and Reinstatement of an employee. This liability on employer also serves the purpose of statutory liability, and these remedies also impose responsibility on the organization that has control and is in the position to take effective remedial action. In the judgment of this case, The Honourable Mr. Justice Le Dain finds section 7 of this act impose liability on the employer of the organization for the acts done by its employees because this section impose restriction on the discriminatory acts that are conducted directly or indirectly. Employer is liable for the discriminatory acts conducted by its employees whether or not they are authorized by the employer. Therefore, judge allowed the appeal (Lexum, n.d., HRCR, n.d.). In my view it is valid if employer is held responsible for the acts of employees in case when employer does not take any measures to prevent sexual harassment at workplace. From the above case law it is clear that employer of the organization are liable under section 7 of human rights act of Canada because sexual harassment is indirectly discrimination between two persons. There are two reasons which can prove that it is important to impose vicarious liability on the employer: First, employers have control over the organization and they are responsible to make the environment healthy for its employees. Employers are the person, who directs the behaviors of their employees, and they have responsibility to share the goods and bad result of their behavior. Employer is entitled for the rewards of the behavior and actions of the employees; similarly he is also liable for the bad behavior and legal liability of the employee. Employer enjoys all the profit earns from the work of its employees, and also grows its enterprise because of the actions of its employees. There we can say that it is the liability of the employer that he also bears the legal liability arises because of action of its employees. Second reason is employer is the person who is the only person that provides some kind of remedies to the victim. In case of injury or harmed to the employee, employer is the most suitable person who can pay these remedies. As we have already stated above that act of Canada and legal system give more importance to provide remedy to the victim, instead of looking for causes of harm. Only employer can give environment at workplace which is free from harassment, compensation for the loss of wages, and Reinstatement of an employee. This liability on employer also serves the purpose of statutory liability, and these remedies also impose responsibility on the organization that has control and is in the position to take effective remedial action (Find law, n.d.). At last we conclude that for this legal issue it is clear that for the benefit of victim it is necessary that employer bears liability for the acts of its employees, and must compensate the victim in case if sexual harassment is occurred at workplace by his employee. Conclusion: This paper contains the discussion related to liability of employer for those actions of its employees which are outside the scope of employment. In this we discuss the legal issue sexual harassment at workplace. In this we first discuss the meaning and law related to sexual harassment in Canada. Supreme Court of Canada defines the meaning of sexual harassment at workplace in such manner that any conduct which is sexual in nature and unwelcomed by the victim is considered as sexual harassment, and section 7 of OHRC and Division XV.1 of Part III of the Canada Labour Code state the provisions related to sexual harassment at workplace. Canada Labour Code states that every employee in Canada has right to work in the environment which is free from sexual harassment. Section 7 of OHRC defines the rights of the person to free from harassment related to sex and any other comment which was related to gender at workplace or housing. In this we state two divergent views related to this legal issue. In some cases it is justified that employers has vicarious liability for the acts of its employees, but in some cases it seems unjustified to held the employer liable for the acts of its employees which are done out of the employment. In this paper we discuss the question and views whether employer should be held liable or not for the acts of its employees, and in last we conclude that it is necessary for justice that employer must held liable for the acts of its employees. References: Canadian Labor Relations. Definition of Sexual Harassment. Retrieved on 5th November 2016 from: https://www.canadianlabourrelations.com/definition-of-sexual-harassment.html. Canadian Labor Relations. Sexual Harassment in the Workplace. Retrieved on 5th November from:https://www.canadianlabourrelations.com/sexual-harassment-in-the-workplace.html. OHRC. Sexual harassment in employment (fact sheet). Retrieved on 5th November from: https://www.ohrc.on.ca/en/sexual-harassment-employment-fact-sheet. Sexassault.Ca. Sexual Assault at Work. Retrieved on 5th November from: https://www.sexassault.ca/work.htm. Government of Canada. Sexual Harassment. Retrieved on 5th November from: https://www.esdc.gc.ca/en/reports/labour_standards/sexual_harassment.page. Government of Canada. Sexual Harassment. Retrieved on 5th November from: https://www.esdc.gc.ca/en/jobs/workplace/employment_standards/labour/sexual_harrassment.page. Canada Labour Code-DIVISION XV.1. UN Women. Employer Liability under Law. Retrieved on 5th November from: https://www.endvawnow.org/en/articles/511-employer-liability-under-law.html?next=512. Canadian Human Rights Commission, (2012). Sexual Harassment Persists in Canada. Retrieved on 5th November from: https://www.chrc-ccdp.ca/eng/content/sexual-harassment-persists-canada. OHRC. Human rights protection against sexual harassment. Retrieved on 5th November from: https://www.ohrc.on.ca/en/policy-preventing-sexual-and-gender-based-harassment/9-human-rights-protection-against-sexual-harassment-0. OHRC. Sexual harassment [16]. Retrieved on 5th November from: https://www.ohrc.on.ca/en/part-i-%E2%80%93-freedom-discrimination/sexual-harassment-16. HRliabrary. Prevention of Sexual Harassment. Retrieved on 5th November from: https://hrlibrary.umn.edu/svaw/harassment/explore/5prevention.htm. Smith, P. J. Letting the master answer: employer liability for sexual harassment in the workplace after faragher and burlington industries. Retrieved on 5th November from: https://www.nyulawreview.org/sites/default/files/pdf/NYULawReview-74-6-Smith.pdf. OHRC. Legal responsibility for human rights at work. Retrieved on 5th November from: https://www.ohrc.on.ca/en/iii-principles-and-concepts/4-legal-responsibility-human-rights-work. Harasement in the workplace: even the CANADIAN human rights TRIBUNAL is not IMMUNE. Retrieved on 5th November from: https://www.bht.com/resources/harassment-workplace-even-canadian-human-rights-tribunal-not-immune-labour-employment. Berta, J. (2003). Employer Liability for the Wrongful Acts of its Employees. Retrieved on 5th November from: https://www.mccarthy.ca/pubs/Wrongful_Acts.pdf. Lexum. Judgments of the Supreme Court of Canada. Retrieved on 5th November from: https://scc-csc.lexum.com/scc-csc/scc-csc/en/item/236/index.do. Canada (Treasury Board) v. Robichaud (1987), 8 C.H.R.R. D/4326 (S.C.C.) Viviers, DJ. (2016). Vicarious liability of the employer in sexual harassment cases: A comparative study. Retrieved on 5th November from: https://scholar.ufs.ac.za:8080/xmlui/bitstream/handle/11660/2557/Vicarious%20liability%20of%20the%20employer%20in%20sexual%20harassment.pdf?sequence=1. Christiansen, W. E. Holding Employers Liable for Employee Wrongs. Retrieved on 5th November from: https://www.hg.org/article.asp?id=19044. Find law. An Employer's Liability for Employee's Acts. https://smallbusiness.findlaw.com/liability-and-insurance/an-employer-s-liability-for-employee-s-acts.html.

Before Act 1 Scene 3 Essay Example

Before Act 1 Scene 3 Essay Before Act 1 Scene 3, Romeo and Juliet got married in private, as their two families had been rivals for years. If the families had found out about this secret arrangement, both Romeo and Juliet would have been disowned. This is an example of Shakespeares use of dramatic irony because in the play only the audience, along with two other characters the friar and the nurse knew that they were married.In Act 3 scene 1, Benvolio and Mercutio were in the public place in Verona. Benvolio tried to convince Mercutio to go home but he refused adamantly. Benvolio wanted to leave before Tybalt and the Capulets arrive but Mercutio refused. The Capulets arrived and Tybalt confronted Mercutio. But Tybalt did not intentionally seek Mercutio to quarrel with him; he wanted Romeo as he gatecrashed the Capulets party. Romeo arrived and saw Mercutio arguing with Tybalt. Romeo tried to keep the peace but Tybalt attacked him.Mercutio jumped in and started a fight with Tybalt. Romeo again tried to interve ne but was not successful and Tybalt accidentally stabbed Mercutio and died. Tybalt, horrified at what he had done, ran off with the rest of the Capulets and Romeo gave chase. Romeo caught up with Tybalt and both of them had a duel. Romeo slayed Tybalt. Realizing what he had done, Romeo ran to the church where friar Lawrence consoled him. In the Town Square however, all the officials and the families of the deceased gathered together and the final judgement of the prince was to banish Romeo.In the play, this scene is a turning point, as the banishment of Romeo created a need for Juliet to escape Verona by the mock death plot in which Juliet would take a concoction that would intoxicate her and cause her to sleep for some days. Her parents would think her dead and bury her and when she awoke she would go and find Romeo. However, it was unsuccessful because the distance created a breakdown in the communication between the lovers because Romeo did not receive Juliets letter explaining her plan. The rumour spread and Romeo heard that Juliet was dead he believed it and poisoned himself, by her side.In the play, many of the characters are portrayed differently. Benvolio is portrayed as a pacifist who tries to keep the peace. We know this because in the film, when the Montague servants encounter the Capulet boys, and start a brawl, Benvolio tries to keep the peace. I do but keep the peace. Put up thy sword, or manage it to part these men with me.Tybalt on the other hand is often presented as an aggressive person for example in Act 1 Scene 1, his response to Benvolios plea to help stop the servants fighting is, What talk of peace? I hate the word, as I hate hell, all Montagues and thee. But in Act 3 Scene 1 he is determined to fight Romeo but he is peaceful towards the other Montagues. When Romeo finally comes, Tybalt says, Well peace be with you, sir: here comes my man. Mercutio is portrayed as a belligerent joker who likes to show off. He even jokes at the hour of h is death.Ask for me tomorrow and you find me a grave man. This shows that he is determined to maintain his honour even if he going to die and this is a pun because it means that he would be dead but what he meant that he would be a sober man. Romeo changes his characteristics quite a lot. At first he is portrayed as a hapless lover and dreamer who is hopeless in romance. Why, such loves transgression; Griefs of mine own lie heavy in my breast. He is then portrayed as a peacemaker in act 3 scene 1. And so, good Capulet, which name I tender as dearly as my own, be satisfied. This is dramatic irony once again as only the audience, the friar and the nurse know that Romeo and Juliet have got married but nobody else so Mercutio is shocked.The film is different from the play in many different ways. In the film, in Act 3 Scene 1, it is clear from the expression on Benvolios face (played by Dash Mikok) that he is apprehensive about the possibilities of impending violence. The audience sees the expression of his face as the Director (Baz Luhrman) shows a close up of Benvolios face to dramatise the anxiety that he is facing.When the Capulet boys arrive, they are dressed in black and they are armed which immediately shows that they want to cause trouble and are ready for a western High Noon shootout. When the Capulet boys confront The Montague boys, Mercutio, being the provocateur that he is, mocks Tybalt and Baz Luhrman dramatises this part as the cameras spin round the two characters as Mercutio attempts to strike Tybalt.One of the most important parts of this scene is the part where Tybalt attacks Romeo. The director dramatises this by showing a close up of Tybalt savagely attacking Romeo who does not strike back. The other most important part of this scene is the part where Mercutio exclaims, A plague in both your houses! In the play, Mercutio utters these words three times, but in the film he screams it out and it echoes over and over again. The weather changes fro m light and sunny but then it goes dark and cloudy and it starts to rain. This is dramatic as it is more powerful the way it sounds and the way Baz Luhrman used the weather to add effect is known as pathetic fallacy.The ending of the scene, when Romeo kills Tybalt, is very important as well. The weather (pathetic fallacy) is also gloomy in this part and when Tybalt and Romeo are driving, the director shows a close up of both their faces, which indicates that something bad is going to happen as they both have the same expression on their faces, which is that of anger and desperation. It is shown in slow motion as well and the director uses that to make it more powerful. When Romeo confronts Tybalt, He screams at him, Either thou, or I, or both, must go with him! This is dramatised as Romeo and Tybalt seem to be the only ones in the square and once again Baz Luhrman (director) uses pathetic fallacy to add to the tension.There are many people to blame for the death of Romeo and Juliet. Firstly theres Tybalt: the impetuous, violent person, the leader of the Capulet boys. He wanted revenge for when Romeo gatecrashed the Capulets party and he is the plays first murderer as he kills Mercutio. Another person to blame for the murder of Romeo and Juliet is Mercutio. If he had listened to the advice of Benvolio and had left the scene, he still would have been alive.Romeo is also to blame for his and Juliets death because he should have told everyone, including Tybalt, that he had married Juliet and this would have stopped Mercutio from getting angry. Oh calm, dishonourable, vile submission! Mercutio thought that Romeo was giving in to Tybalts beatings and this is why he was angry. Also if Tybalt had known, he wouldnt have viciously attacked Romeo. Fate had the biggest hand in the whole play. Even if the lovers had avoided making all those mistakes, fate was out of their hands and each event and mishap in each scene built up to the tragic deaths of both Romeo and Juliet.T his scene links up to the rest of the play as the main themes are love Romeo and Rosaline and then Romeo and Juliet, hate Tybalt and Romeo, Rivalry Montagues and Capulets and fate the death of the lovers. These are all found in the play and the film and they epitomise the play. This scene also shows the biggest duel of the Montague family and the Capulet family. But in the end they realise the wrong they have done and the loved ones that they have lost. Without this scene the play would not have been as powerful because all the previous scenes build up towards this scene. If this scene was not in the play, the ending wouldnt be so climaxed and dramatised and tragic.The reaction of an Elizabethan audience would be different because during the Elizabethan period, they valued honour and pride greatly and the scene when Romeo gate-crashed the Capulets party and wounded Tybalts pride would have caused a negative effect on an Elizabethan audience but it would not cause any effect on t odays audience.

Vygotskys Sociocultural Theory and Hong Kong Essay Example

Vygotskys Sociocultural Theory and Hong Kong Essay Example Vygotskys Sociocultural Theory and Hong Kong Paper Vygotskys Sociocultural Theory and Hong Kong Paper Vygotsky’s sociocultural theory focused on the affect of the surroundings, namely the culture, peers, and adults, on the developing child. Vygotsky proposed the â€Å"zone of proximal development† (ZPD) to explain the influence of the cultural context. ZPD refers to the range of tasks which a child cannot finish alone since they are too difficult, but such tasks can be completed with guidance and aid from more-skilled individuals. The lower limit of ZPD is the level of skill that the children can reach alone, and the upper limit of ZPD is the level of skill that the children can reach with guidance from a more skilled individual, such as teachers, parents and more-skilled peers. Imagine a child is having difficulty writing book reports. With suitable aid from teachers and parents, this child can improve in writing book reports and eventually he/she can finish a detailed book report after reading on his own. In this example, the upper limit of the ZPD is to finish a book report and the assistance provided by the adults is called scaffolding. The assistance provided by the more-skilled individuals will act as a scaffolding to help the children to develop into their upper limit of ZPD. As the children are making progress, the assistance will gradually reduce and removed when the children can complete the task in their upper limit of ZPD on their own. Vygotsky also emphasized on the importance of language in a child’s development. The use of language by children to self-regulate is called private speech. According to Vygotsky, private speech, which Piaget deemed egocentric and immature, is crucial during early childhood years as children use it for planning, guiding and monitoring their actions and help them finish tasks. Vygotsky suggested that children who use private speech will be more socially competent as children must be experienced in using language to communicate with others before making the transition from external to internal speech. In the past, the main emphasis of education of Hong Kong is to get good grades in public exams, as they provide more opportunity towards success. This results in schools focusing on instructing knowledge to students like feeding chickens in a farm and doesn’t really care whether the students understand the knowledge instructed or not. This exam-oriented style of education ignores the students’ development as a whole, and generates many graduates with good grades in school and struggled in workplace. The old educational style of Hong Kong seems not to fit with Vygotsky’s theory. Nowadays, the emphasis of education in Hong Kong seems to be starting to shift from instructing knowledge to assisting students to construct knowledge. As teachers will not only instruct knowledges, but also guides students in finishing tasks such as laboratory exercises and group projects. This implies the ZPD as teachers will now try to dig students’ potential and help students to reach them. Peer mentors are also very common in secondary schools nowadays. Senior form students will volunteer or be recruited by teachers to assist junior form students to finish assignments or group projects. Cross-age mentoring is more common than same-age mentoring. Same-age mentoring will only occur in class, as students with better understanding on the subject will help explain the concepts to other students and assist them in finishing in-class assignments. The peer mentors are suggested to adjust the amount of guidance according to the progress of the tutees. This implies the scaffolding concept and that culture is important in learning as the tutees are making progress, the peer mentors will reduce the amount of assistance by allowing the tutee to think on his own. Also, the mentors can act as a guide to the tutees so that the tutees can learn from both the teachers and peer mentors. This can also stimulate thinking and the mentors can learn from tutoring as well. The idea of private speech is not very popular in Hong Kong, as children exercising it will be deemed stupid and immature, and parents will feel embarassed and think their children have mental issues. In Hong Kong, a â€Å"good† child should be quiet when working. Therefore, the use of private speech when working on tasks are not encouraged. Students in Hong Kong are now encouraged to take part in various activities such as field trips and museum visits. These activities implies the key concept of Vygotsky’s theory: the importance of culture in learning by creating simulations of real-world circumstances and help students to construct the knowledge the teacher desired. However, such activities are not very popular among Hong Kong students as they tend to think such activities as a waste of time and money. In Hong Kong, the culture emphasizes on creating good results with the least effort. This results in students attending expensive tutorials just to get desired grades and attend desired universities. It seems to me that all the effort from the Education Bureau and schools to turn an instructive, exam-oriented education ystem to a more constructive, all-rounded system are ineffective as the students consider this as redundant. It’s very common for students in Hong Kong to say things like â€Å"I prefer past papers to field trips† as past paper will help students get good grades but field trips won’t. To conclude, implications of Vygotsky’s theory can be found in traditional schools in Hong Kong. In my opinion, the key concept of Vygotsky’s theory and other social constructivists’ theory is to stimulate thin kning and construct knowledge through sociocultural activities. This can definitely help students to develop a better understanding of knowledge and stimulate all-round development as a person. However, the education system in Hong Kong, even with addition of elements to exercise Vygotsky’s theory, is still very exam-oriented. This is mainly due to the reluctance of the students and teachers. As students find these additions of elements redundant and a waste of time, some teachers may also find these additional workload is tiring and ineffective.

If computer security is the answer, what is the problem, and how can Essay

If computer security is the answer, what is the problem, and how can computer security solve that problem - Essay Example As stated above, computer security deals with several issues, which are related to technology (Wong & Yeung 2009). Facebook is one of the most popular social network site globally (Kirkpatrick 2010). However, there are several security issues that pose a danger to the users. It is quite clear that Facebook has fallen victim to various security issues such as hacking, hoax applications, counterfeit product pages and affiliate spam among other issues (Stoll 2011). The number of facebook hackings has continually increased in the recent years. There are numerous aspects that make Facebook more prone to hacking since, most individuals usually post their personal information (Sterling 1993). This information enables the hackers steal the personal identity of the account (Reese 2008). Therefore, it is much easier to protect account hacking using computer security. There are several methodologies that can be employed to impede hackers from accessing a facebook account. These methodologies include using a strong password, logging out after finishing, changing the password more often and using an anti-spyware software (Erickson 2008). Using complicated passwords is one of the best ways to deal with facebook security issues. In fact, individuals are advised to use complicated passwords, which hackers are not able to retrieve (Kabay & Bosworth 2011). This will ensure that their personal information and that of their friends is protected against any alterations. Facebook users are also supposed to logout immediately they are done using the social network (Tipton & Krause 2012). This is because another individual can download malware and key loggers which affect privacy terms of the account (Burger 1991). Changing the password more often also reduces the chances of the account being hacked (Mitnick, Simon & Wozniak 2011). This toughens the ability of the hackers to find out