Airborne Express free essay sample

Operational Activities: Unlike Federal Express and UPS, Airborne owned the airport that served as its major hub. As a result, it did not pay landing or facility fees but had to maintain the airport itself and did not share the expenses with other airlines. Airborne’s fleet consisted primarily of used aircraft for which the total cost was around 12. 5 million. This cost per aircraft for Federal Express or UPS was much higher at around $90 million as they purchased new aircrafts. Airborne’s patented cargo containers allowed it to run its aircrafts 80% full compared to 65-70% utilization rate for competitors. Airborne’s parcels were concentrated in major metropolitan areas. 80-85% of the volume was shipped between top 50% metropolitan areas compared to 60% or lower for others. Airborne also distinguished itself by concentrating more on afternoon and second-day deliveries. This allowed them to use trucks more often than its competitors for shipping. This resulted in significant cost saving for Airborne as costs of truck were only one-third of owning and operating similar amount of aircraft capacity. We will write a custom essay sample on Airborne Express or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Airborne also did not maintain retail service centers and instead had roughly 11,000 drop-off boxes. It also used independent contractors for almost 65% of its delivery and pickup services which were 10% less expensive than company owned services. An airborne courier picked up and delivered more parcels per stop than Federal express thereby reducing cost-per-unit by 20% for pickup and 10% for delivery. Technological Activities: Airborne was a follower when it came to technology and only introduced new technology after being certain of a clear derived benefit for its customers. Marketing and Sales Activities: Airborne’s main competitive advantage was its low prices compared to competition and its ability to tailor its services to the needs of particular large business customers (Ex: Xerox special sorting customization for 8am delivery). It did not advertise in mass media and instead relied on its 500-person sales force in courting major accounts. 3 b) Estimated cost of shipping an overnight letter for FedEx: $8. 55 (Source – Exhibit 3) Estimated Cost of shipping an overnight letter for Airborne: 6. 46 (see breakdown in appendix) 3 c) Airborne billed itself as ‘’the flexible, solution-oriented express carrier’’ but was starting to lose this competitive edge as both FedEx and UPS also started offering its trademark 8am custom delivery for any customer. Airborne also competed on its lower priced products. While it could sustain its pricing advantage in the medium term because of its lower operating costs, Airborne needed to invest in technology to automate its operations rather than relying on a manual labour and also improve its services to customers for booking and tracking of shipments. Also, if shorter distance shipments formed a large part of their overall volume, it would make sense to follow distance-based pricing to sustain its pricing advantage with such customers. The old aircrafts that Airborne used would also have smaller life compared to FedEx and UPS and would also be less fuel efficient. If fuel prices were to increase a lot, it could become a significant expense to Airborne and affect its operating costs. Airborne operated in an industry with high capital costs and entry barriers. The recent UPS strike meant that a lot of businesses that traditionally used a single carrier would now use multiple carriers to diversify its risks. But Airborne needed to innovate in multiple aspects of its operations including automation, technological advancements, global expansion, generating greater synergies with partners such as RPS and newer distinctive products to maintain its competitive advantage in the long term. It needed to be wary of the growing ambitions of Postal Services which was planning a major advertising blitz whereas Airborne had no advertising budget and the next big play by the major players to win back market share. HUSKY 3) Husky machines are worth the premium because of its higher production output and superior product quality. For a processor who wants to maximize his outputs, Husky provided with 33. 9% increased productivity for the PET preform machines and at least 16% increased productivity for thinwall margarine that more than accounted for the premium prices. Other than these, Husky machines used less floor space and saved electricity and resin costs. Husky Preform (@20% premium: $1. 2 million per machine compared to $1 million for competitors) With 346. 15 cycles per hour as opposed to 305. 08 cycles per hour for the other manufacturers, Husky is 13% more productive than the other guys. Accounting for the average operating hours, we get 7719. 15 cycles/day for Husky and 5766. 10 cycles/day for the closest competitor. This means that Husky is about 33. 9% more productive than the other guys. Assuming bottle market is perfect competition (i. e. effectively infinite demand at a given fixed price), this alone justifies the 20% premium that Husky charges. Additionally, Husky saves $7. 78/day in resin costs, which is $2839. 7 annually. Husky’s more compact machines saved $522 per year on floor space (assuming $60 per sqft. ) Husky’s more efficient machines also saved $99. 045 worth of electricity per year. Husky Thinwall Margarine (@14. 3% premium: $400k per machine compared to $350k for competitors) With a 6 second cycle instead of a 7 second cycle, Husky’s system was 16% more productive than the competition. This alone justified the 14. 3% premium charged. Husky’s better technology also saved 2. 24 cents per cycle in resin costs due to thinner container walls. Assuming 600 cycles an hour at 16 hours a day and 365 days a year, this turns out to be $78,489. 6 per year. Therefore, Husky’s systems would pay for the premium in resin costs alone every year. APPENDIX Item Cost per unit Cost per unit $1. 09 $0. 07 $0. 21 $1. 37 $0. 87 $0. 07 $0. 20 $1. 13 Flight- and trucking-related expense $2. 44 $1. 93 Hub labor $0. 30 $0. 25 Hub depreciation Subtotal $0. 25 $2. 99 $0. 43 $2. 61 Delivery Labor Fuel Maintenance and depreciation Subtotal $1. 64 $0. 10 $0. 31 $2. 05 $1. 48 $0. 09 $0. 29 $1. 86 Given lower by 10% 62. 5%*90%*FedEx cost+37. 5%*FedEx Cost 62. 5%*90%*FedEx cost+37. 5%*FedEx Cost Advertising $0. 22 $0. 00 Given Nil Sales $0. 21 $0. 18 Income Statement: Sales Marketing(2. 4% revenue)/No. of pkgs per year Information technology+Customer Service $0. 74 $0. 13 Corporate overhead $0. 97 $0. 55 IS: Station+Ground Exp=31% revenue/No. of pkgs per year IT+Cust Service = Station+Ground Pickup and Delivery Labor IT+Cust Service = 2. 48 0. 87 1. 48 Income Statement: General Admin(7. 2% revenue)/No. of pkgs per year Total cost $8. 55 $6. 46 Pickup Labor Fuel Maintenance and depreciation Subtotal Explanation Given lower by 20% 62. 5%*90%*FedEx cost+37. 5%*FedEx Cost 62. 5%*90%*FedEx cost+37. 5%*FedEx Cost Long-haul transport Flight Exp per pkg: 0. 33*0. 3+0. 7 Since 80% is not pkg dependent expense=exp=79%*2. 44 No. of employees(8000)*hrs. per day(4)*wage per hr(7) / pkgs per day(900k) straight line depreciation for total cost of aircrafts owned by Airborne(98*12. 5m) and hub costs Airborne Express free essay sample The environment of the express mail industry has experienced drastic changes over the past decade, let alone since its inception in the 1900’s. As a result of changing tastes amongst consumers, the industry has adopted practices that have allowed it to perform more efficiently in terms of geographic scaling, product assortment of goods being transported, meeting customers varying needs, as well as enhancing the range of service options that carriers offer. Prior to 1997, the concept of â€Å"express delivery† was a new phenomenon to the marketplace and served as a small and marginally profitable business venture. Traditionally, a small proportion of mail and packages were collected, consolidated, shipped, and finally delivered to their destinations as freight within the holds of passenger airplanes. This system was ineffective and lacked fluidity in terms of shipper requirements, carrier costs, pricing policies, and regulatory constraints. Innovation Competition Within the Marketplace It wasn’t until the inception of Federal Express in the 1960’s that helped to challenge both industry officials and consumers alike to envision a more efficient, effective and reliable system of transporting mail. We will write a custom essay sample on Airborne Express or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The invention of systems such as â€Å"hub-and-spoke routing,† where packages from across the nation were lifted to a single airport and sent to their respective destinations, changed the way that express mail was perceived. As a result, almost every business began to use express delivery services, exponentially increasing overall consumer demand. With increased consumer demand came new entrants into the marketplace including industry players such as UPS and Airborne Express. This new competitive landscape challenged corporations within the mail industry to  look beyond the simple delivery of a package. It forced firms to not only look at differentiating themselves on price and features, but to explore advanced logistics technology as a way to focus on quality improvement and customer service. This mix of heightened consumer demand, technological innovation, and increased competition served as a catalyst towards enhancing the profitability and expansion of the express mail industry. However, these innovations severely impacted second-tier players within the market such as BAX Global, DHL Worldwide Express, and the U. S. Postal Service. Smaller competitors were forced to heavily market their product differentiation and become more appealing to niche consumers in order to attain profitiability. It also required smaller companies to look into technology based customer service information systems as a way to streamline their services and enhance customer support. Porter’s Five Forces Analysis Threat of New Entrants – The threat of new entrants within the express mail industry was low due to the fact that the marketplace is currently saturated with three major firms, also known as â€Å"The Big Three,† and six second-tier players. This saturation makes it difficult for competing companies to enter into the market and attain industry shares due to initial high capital requirements and economies of scale. Determinants of Supplier Power – Overall supplier power within the express mail industry was low. Companies such as UPS and Federal Express have little dependency on suppliers and remain profitable by owning their own airline fleets and delivery vans. Rivalry Amongst Firms – The rivalry among firms within the express mail industry was very high. With three major firms – Federal Express, UPS, and Airborne Express – and six second-tier players – BAX Global, SHL Worldwide Express, Emery Worldwide, Roadway Package Systems, TNT Express Worldwide, and the U. S. Postal Service, it becomes increasingly difficult to compete on prices, products, technological innovation and customer support (reference Exhibit 8). Determinants of Buyer Power – Buyer power was extremely high within the express mail industry due to the fact that there are a variety of  different carriers that offer an array of services, catered towards meeting the needs of specific customers. Similarly, there is little to no product differentiation in terms of what services each company offers as well as low switching costs (reference Exhibit 1). Threat of Substitute Products – The threat of substitute products within the express mail industry was extremely high. With similar product quality and general pricing across the board, it makes it easy for customers to switch to another brand or carrier that is more competitive in terms of its product line or features.

Fahrenheit 451 Novel Profile Essay

Fahrenheit 451 Novel Profile Essay Fahrenheit 451 Novel Profile Essay Fahrenheit 451 Ray Bradbury Copyright 1953 159 pages Fahrenheit 451 Novel Profile 1. Although it was written in the 1950s, the novel is set in a futuristic dystopian world sometime in the twenty ­fourth century in an undisclosed city. The tone of the book is poetic and menacing, while bitterly satirical. 2. The main character, Guy Montag is a fireman who burns books in a futuristic American city. In Montag’s world, firemen start fires rather than putting them out. The people in this society do not read books, enjoy nature, spend time by themselves, think independently, or have meaningful conversations. After an encounter with seventeen year old, Clarisse McClellan, Montag begins to question every choice he has made, including his career. He then encounters hardships, including his wife, Mildred, suicide attempt by overdose and an old woman with a stash of hidden books chooses to be burned alive along with her books. Distraught by the unhappiness in his life, he seeks the help of Professor Faber to save these burning books. Eventually, he returns to work on to respond to an alarm on his house, where he is forced to burn it to the ground himself. In rebellion, Montag refuses and kills Captain Beatty with the kerosene hose, becoming a fugitive. On the run, he meets a group of retired professors, who came together in hopes of find lost literature and encourage others to read again. While a war is raging and a bomb just hit, he novel ends with them walking together in the distance in hopes of finding another city to rebuild a proper civilization in. 3. Guy Montag  ­ A fireman who suddenly realizes he is unhappy with his life and starts to search for meaning in the books he is supposed to be burning. He is determined to break free from the oppression of ignorance. He befriends a young teenage girl, who opens his eyes to his ignorance, as well as an old English professor named Faber. With these new found friendships, he is able to break the mold and become a new man. Captain Beatty  ­The captain of Montag’s fire department. Although he is well ­read, he hates books and people who insist on reading them. He is cunning and devious. He almost seems to have the ability to read Montag’s mind. Professor Faber  ­ A retired English professor whom Montag had talked to a year before. Faber admits that society is due to the cowardice of people like himself, who would not speak out against book burning when they still could have stopped it. He hates himself for being a coward, but he redeems himself when he acts with great courage when in the face of danger. Clarisse McClellan  ­ A seventeen ­year ­old girl who opens Montag to the world’s potential for beauty and meaning with her gentle innocence and curiosity. She is an outcast from society because of her odd habits and always asking questions, but she seems genuinely happy with her life until she was killed by a speeding car. 4. Through the novel, the protagonist, Montag goes through many life changes. In the beginning of the novel, he takes pride in his work with the fire department. In the last two years, however, a growing discontent has grown in Montag, a "fireman turned sour" who cannot yet name the cause of his emptiness and disaffection. He characterizes his restless mind as "full of bits and pieces," and he requires sedatives to sleep. His hands, more attuned to his inner workings than his conscious mind, seem to take charge of his behavior. Through his friendship with Clarisse McClellan, Montag perceives the harshness of society as opposed to the joys of nature in which he rarely partakes. When Clarisse teases him about not being in love, he experiences an epiphany and sinks into a despair that characterizes most of the novel. Montag's moroseness reaches a critical point after he witnesses

Term Paper Example | Topics and Well Written Essays - 1250 words - 2

Term Paper Example This paper examines these challenges and how they have impacted on the organization. One of the most challenging facets of organizations today is the need to remain responsible and ethical in their business activities. The past few years have seen many multinationals, big companies, and global association grapple with the issues of unethical behavior. Unethical behavior refers to activities that deviate from the accepted norms, laws, and standards that guide business processes (Blowfield, and Murray, 2014). Essentially, businesses are expected to behave responsibly by acting in a manner that promotes the interests of various stakeholders such as employees, owners, government, and the wider society. However, some organizations find it hard to remain ethical and responsible due to the inability to manage all their huge resources in an efficient way (Crane & Matten, 2010). As such, an irresponsible business on the other hands is one that is involved in dishonest business practices, for instance through concealing or deliberately ignoring issues to do with the environme nt, employees, customers, and the wider society (Blowfield, and Murray, 2014). The most common form of unethical problem that most big companies and associations face is corruption. The International Federation of Football Associations (FIFA) provides a good example of a large organization that has had a rough time dealing with the unethical problem of corruption. FIFA is the body charged with managing football or soccer globally, which is the most popular sport in the world (Skinner & Edwards, 2006). The organization is an amalgamation of various football associations and confederations representing different countries. As such, it is one of the biggest organizations in the world today. FIFA has vast amounts of resources, hence generating a lot of global interest from different parties

Problem, search and selection Research Paper Example | Topics and Well Written Essays - 2500 words

Problem, search and selection - Research Paper Example In Australia, over 1000 people died in 2005 as a result of lower limb ulceration. This was a representation of 8% of people who died of diabetes that year. Every year 10,000 patients with diabetes ulcer foot are admitted in hospitals (Diabetes Australian, 2005, p.7). Diabetic foot infections occur as a result of antibiotic-resistant bacteria and the only way to arrest the ulcers is to arrest bacteria reaction until the wound is healed (Molan, 2006, p.40). One of the effective remedies established to treat diabetes foot ulcers is honey. Clinic studies found that honey has a high anti-bacterial activity making it suitable treatment for bacteria that is anti-biotic resistance (Taks, 2007, p.54). Honey has an antioxidant that provides an anti-inflammatory reaction causing the wound to heal without inflaming the ulcers (Eddy and Gideonsen, 2005, p.533). Patients come to the hospital with serious wounds showing no progress insist on honey treatment, wounds are dressed under the supervision of O.R superintendent at the hospital. The honey treatment has appealed to many clinicians at the hospitals because of its wound healing effects. There is currently no specific research at my institution but this unconventional way of treating wounds may attract attention due to its healing properties. It has been found by French, cooper and Molan (2005, p.228) that wounds heal faster if given due attention. Honey has been used for years for wound treatment and in this case diabetic foot ulcers yet this traditional treatment has barely been recognized in clinical circles. There is need to establish in the clinic practice an effective therapy for foot ulcers (Pierre, 2008, p.342). II.Why honey works well on diabetic ulcers According to Gottrup, Apelaqvist and Price, (2010, p.239) if a wound is infected it will not heal. Too much bacteria stops the cells responsible for repairing the wound from growing. The bacteria’s outer coat also causes inflammation to the wound preventing it from healing. Serious wound infections that do not respond to therapy lead to amputations to stop the wound from spreading. Reports reach clinicians on the use of honey for clearing wounds but most claim it is not yet an assurity (Gottrup, Apelaqvist and Price, 2010, p.239). Because of a lack of a clear benchmark to treat diabetes foot ulcers, the hospital checks wound progress and if there is no improvement the patients are referred to an MFCT department. During treatment the hospital to stop infection educate the patients on importance of self care and foot inspection. Most patients with extreme wounds fear the risk of having their limbs amputated. The debridement, wound dressing, offloading, good glycaemic control, potential antibiotic therapy and vesicular intervention sometimes fail to treat the foot ulcers making the wounds deteriorate which leads to disfigurement, burns or amputation. In 1999 Capilano, Australia’s largest honey company came up with honey products a nd sold it to pharmacies, clinics and hospitals for medicinal purposes. The main aim was to use the honey products for healing untreatable wounds, ulcers and burns (Diabetes Australia, 2005, p.7). The therapy instead of going through the four stages, it arrests the problem at the inflammation stage. The anti-oxidant in honey was discovered two millenniums ago and that is why it is used to treat sunburn Gottrup, Apelaqvi

Conference Project Plan Essay Example | Topics and Well Written Essays - 1250 words

Conference Project Plan - Essay Example and that is only possible when people are abreast to the current and emerging trends in the profession through themed conferences and induction workshops. The conference will also provide a platform for comparing notes and mentoring. Continued fruitful engagements and consultation will be made possible by exchanging contact cards. Being a milestone conference, a lot of activities will be executed in the planning process to ensure that the conference is a success. A team has been assembled to oversee the planning process, and duties have been assigned. The planning has activities such as publicity, correspondences, reservations, logistics and more. Division of roles will ensure that each planning activity is given the maximum concentration it requires, and, therefore, that each activity is a success. The risks listed above have been identified as the most serious and their occurrence may affect the success of the conference in the most negative of ways. Take for instance absentee guests. The planning team has identified five key speakers to grace the conference, two being foreigners from Kuwait and China. All these guests have different presentations to make, and should any one of them be absent for whatever reason, a gap will result that would be difficult to fill. The planning team has created communication channels with those the important guests of the day to ensure that they communicate their likely absence in good time to enable the conference planning team to get a replacement. Another option is for the speaker to send someone to stand in for them, and adequately make up for their absence. The latter option will be the most workable because it will ensure that not many adjustments are made to accommodate a different person. Over-attendance is another risk that is likely to occur, though a positive one. The conference planning team plans to send invites to about 100 persons, 80% of whom are projected to attend. There is, however, a risk associated with

Secret trusts in Blackwell v Blackwell

Secret trusts in Blackwell v Blackwell For the prevention of fraud equity fastens on the conscience of the legatee a trust which would otherwise be inoperative: in other words, it makes him do what the will has nothing to do with, it lets him take what the will gives him, and then makes him apply it as the Court of Conscience directs, and it does so in order to give effect to the wishes of the testator, which would not otherwise be effectual per Viscount Sumner in Blackwell v Blackwell [1929] A.C. 318, 335. Discuss this view explaining the practical and legal problems the approach creates, the nature of the fraud, and whether it is a sufficient justification for the acknowledgment of both fully secret and half secret trusts. Let us commence with a brief examination of the factual circumstances which occurred in this case: A testator, by a codicil, bequeathed a legacy of  £12, 000 to five persons ‘to apply for the purposes indicated by me to them. Prior to the execution of this codicil, the terms of the trust were communicated to the legatees and the trust was accepted by them. The beneficiaries were the testator’s mistress and her illegitimate son. The plaintiff sought from the courts a declaration that no such valid trust in favour of the objects had been created on the ground that parole evidence was inadmissible to establish such a trust. Approaching this factual situation as a probate lawyer, one would not be criticised for suggesting that the trusts in question were invalid for failure to comply with the formality requirements of s9 of the Wills Act 1837, which require a will, â€Å"or any other testamentary disposition†, to be in writing, signed by the testator and two witnesses. Viscount Sumner in Blackwell v Blackwell[1] however did find that these trusts were valid, in spite of this statute: The above excerpt, from the dicta of Viscount Sumner in Blackwell v Blackwell, argues that the enforcement of a semi-secret trust does not in fact contravene the aforesaid statutory provision. Viscount Sumner reasons that the trust in question is in fact created inter vivos, and as such operates outside of the will; the testator communicated the trust to the proposed trustees who accepted it, the trust becoming fully constituted upon execution of the will and transfer of the trust property to these trustees. In this way, he argues that enforcement of the trust is not due to the will document itself, rather the previous agreement made between the trustees and testator; secret trusts therefore operate outside of the will itself and as such are not subject to the formality requirements contained in s9 of the Wills Act 1837: the whole basis of secret trusts, as I understand it, is that they operate outside the will, changing nothing that is written in it, and allowing it to operate accor ding to its tenor, but then fastening a trust on to the property in the hands of the recipient.[2] Viscount Sumner therefore argues that the enforcement of semi-secret trusts should be governed by trust law and not through the rules of probate. This conclusion is certainly neat, and prima facie, does seem to satisfy the concerns of the probate lawyer, but if Viscount Sumner’s argument is to be accepted, and we are to submit to the notion that the applicable principles to be applied to the above facts lie within the sole jurisdiction of trust law, then surely we could expect that there would be a vast body of case law which we could rely upon to support his argument. The truth however is that, despite its beauteous simplicity, there are real legal problems in reconciling this theory with our orthodox principles of trust law; the permission of a trust, which purports to bind after-acquired property, is irreconcilable with the established trust law rule that it is impossible to declare an immediate trust of future property[3], or a trust which binds such property whenever in is received[4]. These are not minor concerns, nor the only concerns: Critchley[5] argues that this viewpoint is also flawed in that Viscount Sumner has confused the notions of â€Å"outside the will† with â€Å"outside the Wills Act†, incorrectly relying on the reasoning in the case of Cullen v Attorney General for Northern Ireland[6], which was a decision relating to tax statutes rather than to the formal requirements of the Wills Act, and was as such within an entirely different legal context On top of this, Pearce and Stevens[7] convincingly argue that the case of Re Maddock[8] is wholly inconsistent with Viscount Sumner’s view: In this case, a testatrix, by her will, left her residuary estate ‘absolutely’ to X whom she appointed one of her executors. By a subsequent memorandum communicated to X during her lifetime, she directed X to hold part of the residue upon trust for named beneficiaries. There were insufficient assets to pay the debts of the estate. The legal issue was whether or not the secret beneficiaries took their interest subject to the payment of the debts. Cozens-Hardy LJ argued that â€Å"†¦the so called trust does not affect property except by reason of a personal obligation binding the individual devisee or legatee. If he renounces or disclaims, or dies in the lifetime of the testator, the persons claiming under memorandum can take nothing against the heir at law or next of kin or residuary devisee or legatee.† Viscount Su mner’s reasoning however suggests that since the trustee takes as trustee on the face of the will, the trust should not fail in the ways suggested by Cozens-Hardy in the above dicta. The legal problems and inconsistencies with Viscount Sumner’s justification must lead us to the conclusion that such trusts cannot be accounted for under the rules of inter vivos trusts; we must therefore accept that their existence does in fact mark a departure from the Wills Act 1837. This does not mean that such a view is necessarily unjustified and outside the scope of Equity’s jurisdiction; after all, Equity is the ‘court of conscience’, and as the age old maxim states ‘Equity will not allow a statute to be used as an engine of fraud’. Therefore, if it can be demonstrated that the permission of semi-secret trusts is preventing such fraud, then, despite the legal problems and inconsistencies discussed above, we may still be able to find adequate justification for the existence of such trusts. As Vaughan Williams L.J. asserted, in the case of Re Pit Rivers [1902][9], â€Å"†¦the court will never give the go-by to the provisions of the Wills Act by enforcing any one testamentary disposition not expressed in the shape and form required by the Act, except in the prevention of fraud.† Clearly therefore, whether or not this justification will apply to any given case depends upon which definition of ‘fraud’ is subscribed to in that case. In McCormick v Grogan[10], the ‘fraud’ being protected was that of the secret trustee: it is only in clear cases of fraud that this doctrine has been appliedcases in which the Court has been persuaded that there has been a fraudulent inducement held out on the part of the apparent beneficiary in order to lead the testator to confide to him the duty which he so undertook to perform. The protection of this type of fraud has been held out, and confirmed in subsequent cases, to be the traditional justification for the existence of the doctrine of secret trusts. However, in the case of semi-secret trusts [such as the type of trust at issue in the case of Blackwell v Blackwell] such fraud is not possible; the face of the will makes it quite clear that the secret trustee is not to take the property beneficially, a nd should the contents of the trust be denied by that trustee, the property would return to the estate by way of resulting trust. And yet in cases involving half-secret trusts, we can still see the courts employing justification-arguments based on fraud. In such cases, a wider conception of ‘fraud’ has been employed; â€Å"it is not the personal fraud of the purported legatee, but a general fraud committed upon the testator and the beneficiaries by reason of the failure to observe the intentions of the former and of the destruction of the beneficial interests of the latter.† It was this argument put forward in the case of Riordan v Banon[11]: â€Å"it appears that it would also be a fraud though the result would be to defeat the expressed intention for the benefit of the heir, next of kin or residuary donee,† and it was this passage which was cited by Hall V.C. in the case of Re Fleetwood[12], a case which was relied upon by Viscount Sumner in the formulation of his judgement: â€Å"It seems to me that, apart from legislation, the application of the principle of Equity in Fleetwood’s case†¦ was logical, and was justified by the same considerations as in cases of fraud and absolute gifts. Why should equity forbid an honest trustee to give effect to his promise, made to a deceased testator, and compel him to pay another legatee, about whom it is quite certain that the testator did not mean to make him the object of his bounty?† Challinor[13] argues that the ‘fraud theory’ has been extended in an artificial way in order to encompass a justification of half-secret trusts and the modern case law. A huge flaw exists in making such an extension; she argues that equity’s willingness to respect a testator’s wishes where that testator has not met the formality requirements as stipulated by s9 of the Wills Act is inconsistent with its approach to other commonplace situations in which a testators wishes are not respected by Equity in the same way: for example, â€Å"purported beneficiaries under ineffective wills are routinely deprived of property which testators or settlers would desire them to have, simply because wills and trusts have not been put into effect in the proper manner.† She argues that the traditional equitable maxim that â€Å"equity will not permit a statute to be used as an engine of fraud† must be adapted to something more like â€Å"equity will not allow a statute to be used so as to renege on a promise† if it is to fit within the situations envisaged in Blackwell v Blackwell. The effect of such a mild form of fraud theory is to shift the focus â€Å"onto potential, rather than actual, wrongdoing†¦ the policy aim underlying it is thus proactive (or preventative) rather than reactive (or curative).† In conclusion therefore, Viscount Sumner’s view as to the enforcement of secret and semi-secret trusts is one which creates a number of practical problems. It gives testators a valid reason for not observing the statutory formalities normally applicable in making a will. These statutory formalities are in place for the very purpose of preventing personal fraud, and in light of this, it seems odd that Viscount Sumner should support a view which in itself gives testators the option of bypassing these precautions and thus increasing their risks to such fraud, especially in light of the fact that the underlying justification in his viewpoint is one of ensuring that the testator’s true intentions are honoured. I must therefore conclude that in light of its legal problems and inconsistencies, the artificial nature of the ‘fraud’ it seeks to prevent, the practical problems which arise as a result of acknowledging such trusts, the view expressed by Viscount Sumner in the case of Blackwell v Blackwell does not provide a sufficient justification for the acknowledgment of both fully secret and half secret trusts. Bibliography Critchley, Instruments of Fraud, Testamentary Dispositions, and the Doctrine of Secret Trusts (1999) 115 L.Q.R. 631 Pearce Stevens, The Law of Trusts and Equitable Obligations (2nd ed., London, 1998) Conveyancer and Property Lawyer 2005. â€Å"DEBUNKING THE MYTH OF SECRET TRUSTS† Emma Challinor Moffat, Trusts Law Text and Materials 3rd ed Footnotes [1] [1929] A.C. 318, 335 [2] Megarry V.C in Snowden, Re [1979] 2 All E.R. 172 at 177, expressing the same viewpoint as Viscount Sumner in Blackwell case [3] Williams v C.I.R. [1965] N.Z.L.R. 395 [4] Permanent Trustee Co v Scales (1930) 30 S.R. (N.S.W.) 391 [5] Critchley, Instruments of Fraud, Testamentary Dispositions, and the Doctrine of Secret Trusts (1999) 115 L.Q.R. 631 at 635 and 641 [6] Cullen v Attorney-General for Ireland (1866) L.R. 1 H.L. 190 at 198, per Lord Westbury. [7] Pearce Stevens, The Law of Trusts and Equitable Obligations (2nd ed., London, 1998), p.222 [8] Maddock, Re [1902] 2 Ch. 220 [9] Pit Rivers, Re [1902] 1 Ch. 403 [10] McCormick v Grogan (1869) L.R 4 H.L. 82 at 89 [11] (1876) 10 Ir. Eq. 469 [12] (188) 15 Ch.D. 594 at 606-607 [13] Conveyancer and Property Lawyer 2005. â€Å"DEBUNKING THE MYTH OF SECRET TRUSTS† Emma Challinor

Database Environment Paper Essay

After 45 minutes of walking through the cummers museum and realizing that Jacksonville is home to four beautiful museums. These museums will not only captivate you but also tell you a story in history. By understanding this I walk through the commer museum in amazement but being from a IT background my mind soon begin to wonder how do they keep track all of these beautiful works of art. I mean there’s things that have to be taken into consideration. In example who is the artist, the location where the art is display, can it be or is it on loan, the year the artist created the artwork. After thinking about this for a few minutes a database popped in to my mind. A database management system can easily do all of these things and more. A museum can choose a variety of databases to complete this task but just for explanation purposes we’re going to use Microsoft access to help us understand how a database can complete the task of tracking the artwork and giving us an accurat e account and location. Let’s keep in mind while we are designing and building the database three words; real, conceptual, and representations if we keep these three keywords at the forefront of our design we will design a usable and efficient database. Simply put the design of a database is to define the structure of data that can be queried and give out meaningful information to the end-user. And will design database also allows for easy maintenance and upkeep. With over 5000 works of arts in the cummers museum there’s a lot of data that has to be enter into access on the front and ongoing in order for the museum to be able to used the software. But in order to do this we must first understand how the data or where the data is entered in Microsoft access. Data is stored in what is called a tables, each table consists of data about a specific subject in example; painters name, date art was created, location ,Address, zip code,  city. By putting data in a table that is specific it allows for changing of data in specific table and it will automatically populating throughout the whole database. This also allows for different types of queriers making the database efficient. Let also look at what is a query. A query is a search by the end users which displays usable information. A query can sometimes and most time often will also display subsets of data as well. The subsets of the table is referred to as A field or as an attribute. To understand this a little better you can think about the squares in Microsoft excel those squares are fields and/or attributes is a place with database tables used to store one piece of given data. When entering data into a table or A field is called an entry. An entry is data that needs to be tracked. Now the question how can all of this information help the museum track there artwork. When billing the initial database you can one can use the artwork name as the interest in the fields or attributes can be the artist name the date the artist created the piece of artwork artwork that exactly where the artwork is located inside the singing is the artwork being load out or is it all from another museum what does the museum that peace of artwork. After entering all of the fields and tables we can then run a ERD report to help us see how the database is coming along by doing so were able to see from it overview what tables relate to what and in sure that all of the tables that need to t alk to each other are doing so. It is easy to see if you museum created a database as explained above that you can effortlessly track each keys of work. References What is a Database. (2011). Retrieved from http://databases.about.com/od/specificproducts/a/whatisadatabase.htm What Is Database Architecture. (2003-2014). Retrieved from http://degreedirectory.org/articles/What_is_Database_Architecture.html Coronel, C., Morris, S., & Rob, P. (2013 ). Database Systems (10th ed.). : Cengage Learning

Life Cycle of a Butterfly Essay

Introduction Lifecycle refers to the stages of growth and development of a living thing. All living things go through different stages of development throughout their lives. Change in actions and behaviors are deeply associated with the changes in the stages of life. Butterfly is such an insect, which has a complete lifecycle consisting of four separate stages. In this paper, we will discuss the lifecycle of a butterfly in order to get an understanding of all stages of growth and development of a butterfly. Stages of Development A butterfly’s growth and development process is known as metamorphosis. There are four stages of development in the life of a butterfly. Each stage is unique and represents a different life structure of a butterfly. The four stages of development that a butterfly goes through include Egg, Larva, Pupa, and Adult butterfly. Egg is the very first stage of a butterfly’s life. A female butterfly lays 10 to 100 tiny eggs at a time on the leaves of the plants. Butterflies select the leaves for eggs based on the food choice of the caterpillars. A butterfly lays her eggs only on the leave, which caterpillars like to eat. Each type of butterfly has a different choice of leaves, which it uses to lay down the eggs. â€Å"The food source needed in a butterfly habitat varies among species† (Barrett, 2011). It takes nearly five to ten days for a caterpillar to emerge from an egg. The second stage of a butterfly’s lifecycle is one in which an egg hatches into a caterpillar. A butterfly, in the form of a larva or a caterpillar, eats the maximum amount of food in this stage. The stage of caterpillar is the primary growth stage of a butterfly. A caterpillar is a work-like form of butterfly with a pattern of beautiful stripes on its skin. Caterpillars have just one aim, which is to eat more and more food. It even eats the shell of the egg from which it comes out. â€Å"The caterpillar hatches from the egg and usually the first thing it does is eat the egg shell† (Ballard, 2009). There is no specific food, which a caterpillar eats. Different types of caterpillars eat different kinds of food. Each species of butterfly has a specific family of host plants from which caterpillars take their food (Ballard, 2009). Some caterpillars like to eat fresh leaves whereas some types of caterpillars prefer old leaves. There is a species of caterpillars known as Harvester butterfly’s caterpillars. Harvester caterpillars like to eat aphids that are present on different kinds of plants. The Harvester butterflies lay their eggs near aphid colony in order to provide a good amount of food to their caterpillars. This stage of a butterfly’s lifecycle lasts for two to five weeks depending on the living conditions and type of the caterpillar. Pupa is the third stage of a butterfly’s lifecycle. In this stage of life, the butterfly in the form of a pupa, hangs itself in an upside-down position to a twig. Another change, which occurs in this stage, is the growth of a tough flexible shell outside the body of the pupa. The structures of a caterpillar are deformed and a new adult butterfly’s structure is formed. This stage is also known as the resting stage of butterfly’s life. The habit of continuous eating goes away in this stage. A pupa appears to be dead but inside the shell, the process of transformation continues. â€Å"It is generally incapable of movement but is able to move certain body parts† (Kumar, 2011). This stage of a butterfly’s lifecycle lasts for one to two weeks. Adult butterfly is the last stage of a butterfly’s life. In this stage, a fully developed adult butterfly comes out of the shell. The head, thorax, legs, swollen abdomen, and wings come out of the shell one by one. A butterfly rests for a while in order to let its structures become dry and hard. Once the structures of a newly emerged butterfly become hard, it becomes ready to fly. A butterfly usually lives for two to three weeks. However, there exist some types of butterfly, which can live for months. Conclusion Summing it up, all living things go through different stages of development, which represent their lifecycles. A butterfly has four stages of life, which include egg stage, caterpillar stage, pupa stage, and the adult butterfly stage. A butterfly shows different nature and habits in each stage of life. An adult butterfly represents the last stage of a butterfly’s lifecycle in which a butterfly becomes ready to fly. References Ballard, K. (2009). Butterfly Life Cycle – The Caterpillar. Retrieved from http://ezinearticles.com/?Butterfly-Life-Cycle—The-Caterpillar&id=2005048 Ballard, K. (2009). What Do Caterpillars Eat?. Retrieved from http://ezinearticles.com/?What-Do-Caterpillars-Eat?&id=2133512 Barrett, M. (2011). What Is in a Butterfly’s Habitat?. Retrieved from http://www.wisegeek.com/what-is-in-a-butterfly-habitat.htm Kumar, M. (2011). Things To Know About Butterfly Life Cycle. Retrieved from http://ezinearticles.com/?Things-To-Know-About-Butterfly-Life-Cycle&id=6096961

South African Population Registration Act of 1950

South African Population Registration Act of 1950 South Africas Population Registration Act No. 30 (commenced on July 7) was passed in 1950 and defined in clear terms who belonged to a particular race. Race was defined by physical appearance and the act required people to be identified and registered from birth as belonging to one of four distinct racial groups: White, Coloured, Bantu (Black African), and Other. It was one of the pillars of Apartheid. When the law was implemented, citizens were issued identity documents and race was reflected by the individuals Identity Number. The Act was typified by humiliating tests which determined race through perceived linguistic and/or physical characteristics. The wording of the Act was imprecise, but it was applied with great enthusiasm: A White person is one who is in appearance obviously white - and not generally accepted as Coloured - or who is generally accepted as White - and is not obviously Non-White, provided that a person shall not be classified as a White person if one of his natural parents has been classified as a Coloured person or a Bantu... A Bantu is a person who is, or is generally accepted as, a member of any aboriginal race or tribe of Africa... A Coloured is a person who is not a White person or a Bantu... Racial Test The following elements were used for determining the Coloureds from the Whites: Skin colorFacial featuresCharacteristics of the persons hair on their headCharacteristics of the persons other hairHome language and the knowledge of AfrikaansThe area where the person livesThe persons friendsEating and drinking habitsEmploymentSocioeconomic status The Pencil Test If the authorities doubted the color of someones skin, they would use a pencil in hair test. A pencil was pushed in the hair, and if it remained in place without dropping, the hair was designated as frizzy hair and the person would then be classified as colored. If the pencil dropped out of the hair, the person would be deemed white. Incorrect Determination Many decisions were wrong, and families wound up being split and/or evicted for living in the wrong area. Hundreds of colored families were reclassified as white and in a handful of instances, Afrikaners were designated as colored.  In addition, some Afrikaner parents abandoned children with frizzy hair or children with dark skin who were considered outcasts. Other Apartheid Laws The Population Registration Act No. 30 worked in conjunction with other laws passed under the apartheid system. Under the Prohibition of Mixed Marriages Act of 1949, it was illegal for a white person to marry someone of another race. The Immorality Amendment Act of 1950 made it a crime for a white person to have sex with someone from another race. Repeal of The Population Registration Act The South African Parliament repealed the act on June 17, 1991. However, the racial categories set forth by the act are still ingrained in the culture of South Africa. They also still underlie some of the official policies designed to remedy past economic inequalities. Source War Measures Continuation. Population Registration. South African History Online, June 22, 1950.

Saudi Arabia essays

Saudi Arabia essays The Kingdom of Saudi Arabia, occupying most of the Arabian Peninsula, is located in the southwestern corner of Asia. It covers an area about one-fourth the size of the United States. More than half of its total area is desert terrain. The capital of Saudi is Riyadh, which is located in the central region of the country. Saudi Arabia's official language is Arabic, although English is also spoken in the Kingdom, most commonly in the business community. The official religion of Saudi is Islam. Two of the holiest Islamic cities, Makkah and Madinah, are located within its borders. Makkah is the birthplace of the Prophet Muhammad, and is the focal point of the Islamic Pilgrimage. Madinah is where the Prophet Muhammad lived. Also, The Kingdom's Judicial System stems from Islamic Law and the Holy Qur'an, which still bases its beliefs on the "eye for an eye" form of punishment. Hence, many wrongdoers swiftly lose their limbs and, in some cases, their lives to a well place axe in the infamous "Chop-Chop" square. There are approximately 21 million people in the Kingdom. Although most are Saudi Nationals, many outsiders from the U.S. and surrounding Arabic nations come to Saudi Arabia for various employment opportunities. In fact, a large percentage of Saudi nationals do not work because of the lucrative returns from oil revenues. For those less fortunate, the Saudi work week is from Saturday through Wednesday with the weekend being Thursday and Friday because the Muslim holy day of the week is Friday. Businesses are usually closed during the heat of the day, for prayer and resting. Business hours are generally 8:00am-noon and 4:00pm-6:00pm. The Kingdom of Saudi Arabia is obviously a monarchy headed by King Fahd Bin Adbul Aziz. The government is made up of the King, the Crown Prince, and, similar to the U.S. cabinet, the ...

Annotation of articles Essay Example | Topics and Well Written Essays - 2500 words

Annotation of articles - Essay Example In fact, The Boston Globe is among the top ten newspaper websites in America. This undoubtedly shows that it is a trusted source of information. The fact that it has been done by an experienced movie critic, Burr, who is definitely aware of what to put in and what not to makes it even more reassuring. It is definitely an official review. Reflections of War by Stanley Kauffmann. Kauffmann, Stanley. â€Å"Reflections of War.† New Republic. 236.10/11 (3/5/2007). Academic Search Premier. Web. 6 September 2012. In his review, Kauffman starts by giving a description of the place covered in the movie, Grbavica: The Land of My Dreams. In fact, it is clear that he understands the plot. He is also very well informed since he even offers an account that the writer-director of the film lives right across the place. He also offers a succinct description of the characters depicted and the events that take place. Kauffman also offers an account of the movie Close to Home, which is a legal dr ama showcasing the existence of crime in the streets. Here, Kauffman also offers a clear account of who is involved and what happens. Being a movie critic, this does not go without an opinion from his perspective. Kauffman himself is an experienced film and theatre critic as well as a talented author and editor. The New Republic on the other hand is a genuine source. In fact, the magazine has been around since 1914. The magazine itself is very informative in the disciplines of arts and politics. Post War: Sarajevo conflict was hell, but what comes after is another battle by Ella Taylor. Taylor, Ella. â€Å"Sarajevo conflict was hell, but what comes after is another battle.† Villagevoice.com. Feb 6, 2007. Web. 6 September 2012. Taylors review begins with a reflection of what is happening today in war torn countries as well as what has been there in the past. She also gives an account of the effects of past wars in various countries. Despite being less graphic, Taylor describes the movie Grbavica: The Land of My Dreams as being one that brings back sad memories of the war which is another emotional battle. The review particularly highlights the plight of women, and especially single mothers who have to carry heavy burdens of being sole providers, in a male dominated society. Ella Taylor is an experienced movie critic and holds vast experience writing for various media companies in America. Villagevoice media on the other hand is an informative and genuine features and news website. The source of information is therefore legitimate. This information is very helpful in understanding the aftereffects of wars and genocides. The conflict in Sarajevo clearly shows what goes on in the lives of war victims physically, emotionally and psychologically. It is clear that although the war has ended, every victim still continues to struggle with memories and emotions arising from past events. Looking to the Future, Living with the past by Stephen Holden Holden, Stephen . â€Å"Looking to the Future, Living with the past.† nytimes.com. February 16, 2007. Web. 6 September 2012. Life after war is always haunted by memories and bitterness from the past. In his review, Holden clearly highlights this. Even when the war remains in the past, victims inevitably carry it with them. Memories of what happened cannot be rubbed from their minds and every time they come back with a

Quality Data Collection Essay Example | Topics and Well Written Essays - 1250 words

Quality Data Collection - Essay Example Lack of proper data collection strategies results in wastage of hospital and patients resources since some results done are insignificant while others are annihilated. This paper focuses on data collection tools in emergency departments for blood culturing and the tools used in critical value reporting. The paper also elucidates on how the tools operate and compares how the tools operate. Improvement in data collection is vital for apposite analysis, diagnosis, treatment, and running of health amenities. Patience in the emergency department is often febrile and thus blood cultures are often obtained devoid of following the guidelines. However, most blood cultures ordered from the emergency departments are rarely utilized in management of the patient’s health. They thus end up being a source of unnecessary costs to the patients as well as the hospital. Another factor that declines the services of most community hospitals is excessive delays in defining and reporting of critical value results. Critical laboratory values have imperative significance on determining prompt treatment or actions that health provider ought to undertake. Most decisions and patient diagnosis depend on analysis of laboratory reports thus improvement in organization of laboratory services can improve on service provision. It is therefore vital to improve on timelines of reporting critical values (Tintinalli, et al, 2004). Blood Culture Contamination Rate in the Emergency Department Blood cultures are crucial in detecting conditions such as sepsis in the emergency departments. However, various researches show that most hospitals do not use blood culture results efficiently in clinical management of patients. The main problem in blood culturing is the inability to differentiate between contaminated cultures with true bacteraemia (Hall, & Lyman, 2006). To reduce errors and increase utilization of blood culture results, it is important to improve on tools used in monitoring performance information. It is recommendable that culture be collected only when clinically required. It is also important to use proper sampling techniques to prevent contamination. Tools used in blood culturing in the emergency department include culture bottle and needles. Enhanced collection of uncontaminated blood cultures is vital and can be done by proper disinfection of surfaces before drawing blood samples as well as using sterilized culture bottles. Use of surgical needles for blood sampling leads to contamination especially if proper sterilization is not done on the patients skin (Tintinalli, et al, 2004). Proper management of the data obtained after blood culturing is fundamental in improving the significance of the samples in management of emergencies. Another tool used to collect blood culture in the emergency department is automated blood culture technology that is capable of differentiating between positive and negative culture (Tintinalli, et al, 2004; Hall & Lyman, 2006). Crit ical Value Reporting Clinical value reporting provides mechanism for determining and reporting critical laboratory reports requiring urgent response. Critical values are determined differently by different hospitals with most choosing to use published values. Others make use of non-laboratory medical staff advice while others use inter-laboratory comparison, manufacturer proposals, or conduct internal studies to come up with their own