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Our staff of freelance writers includes over 120 experts proficient in AUSTRALIAN LAW OF DEFAMATION, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your AUSTRALIAN LAW OF DEFAMATION paper at affordable prices ! The tort of defamation consists of the communication of a defamatory meaning and of concerning the plaintiff to a person other than the plaintiff. This tort is actionable per se and the onus is on the plaintiff to prove on the balance of probability that the meaning relied upon by the plaintiff was conveyed by the publication and that meaning was defamatory to him or her.


The elements of this tort


1. defamatory matter


Defamatory matter may be written or oral or published in some other tangible form. The matter itself is not defamatory unless a person of average intelligence could reasonably place upon it an interpretation which is defamatory. That may be so even if known to be false. The matter extends to both imputations concerning moral characteristics and those concerning ability, if such imputations are likely to discredit the person.


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The natural and ordinary meaning is the basis for construction of words. Accordingly, any strained or utterly unreasonable interpretation is rejected. Since meaning must be taken from the context in which the publication occurs, a defendant may be able to establish to the satisfaction of a jury that in the particular context an imputation amounts to mere general abuse and is not defamatory in the circumstances.


Ø In the present case, it is more likely that this element will be found to have been satisfied as there is clear imputations concerning the ability of Mr Williams and such imputations are made and are likely to discredit him. It is hard to see in this particular facts how the comments are merely a generally abuse when Mr Taylor is recommending someone to do the work.


. Reference to the Plaintiff


The reference to Mr Williams is clear in the email and this element is also satisfied.


. Publication


There is no defamation unless the matter is published to a third party, otherwise there would be no injury to reputation. Publication to a single person is sufficient (Pullman-v-Walter Hill & Co). This is also satisfied in these facts.


Defences


The truth or falsity of a publication is not relevant to the determination of whether the publication conveys a defamatory meaning or is defamatory to the plaintiff. (Vast-v-Queensland Newspapers Pty Ltd [11] QD R 54). At common law, a defamatory publication is presumed false in the absence of a plea of the defence of truth (Allworth-v-John Fairfax Group Pty Ltd (1) 11 FLR 54 at 66). In all jurisdictions except New South Wales a defamatory publications is presumed false. In New South Wales, truth is only a defence for the publication of a defamatory imputation which relates to a matter of public interest or is published under qualified privileges (section 15() of the Defamation Act 174 NSW).


The defence of a fair comment is only available where the matter relates to a matter of public interest (section of the Defamation Act)


The defendant may raise as a defence an offer of amends made to the plaintiff under section 7 of the Defamation Act.


The malice of the defendant is relevant to damages only if it adds to the actual harm suffered by the Plaintiff.


The defences of absolute and qualified privilege, which exist under the common law in all jurisdictions and are variously modified by legislation, allow for greater freedom of speech than would otherwise be permitted.


The defence of absolute privilege exists at common law and under legislation in all jurisdictions


The common law defence of qualified privilege remains applicable with statutory modifications in New South Wales.


Common law


At common law, a publication is made on a privileged occasion if it is made without malice by a person in discharge of some public or private duty, whether legal, social or moral for the purpose of pursuing or protecting some private interest. It must be made to someone who has a corresponding interest in receiving the communication.


Statutory defence of qualified privilege In New South Wales


A statutory defence of qualified privilege is available where, in respect of matter published to any person


(1) the recipient has an interest or apparent interest in having information (information includes both fact and opinion) on some subject;


() the matter is published to the recipient in the course of giving to him or her information on that subject; and


() the conduct of the publisher in publishing that matter is reasonable in the circumstances.


The publication must have been published on an occasion of qualified privilege, whether at common law or under the legislation, and be relevant to that occasion, that is, relevant to the provision of the information on the subject matter in which the person has an interest or apparent interest. That the publication was for reward does not affect the availability of the defence. The defence is defeated by proof of malice on the part of the defendant.


Reasonableness of publication


It is the publisher's conduct in publishing defamatory imputations and not in conveying information on a subject of public interest which must be reasonable. Whether the conduct of the publisher in publishing was reasonable in the circumstances involves a consideration of all the circumstances leading up to and surrounding the publication. As the circumstances will vary infinitely from case to case it is impossible and unwise to attempt any comprehensive definition of reasonableness in such a context. Relevant factors include


(1) the manner and extent of publication;


() the defendant's belief in the truth of the publication5 and knowledge of the likelihood of conveying a misleading impression;


() the connection between the subject and the imputation and the reasonableness of the imputations in fact conveyed;


(4) whether any comment was fair and based upon the facts as stated; and


(5) what care was exercised before publication.


The defendant must establish that


(1) he or she exercised reasonable care in making proper inquiries in relation to the accuracy of his or her sources;


() his or her conclusions, whether statements of fact or opinion, followed logically, fairly and reasonably from the information obtained;


() the manner and extent of the publication did not exceed what was reasonably required in the circumstances; and


(4) each imputation intended to be conveyed was relevant to the subject matter which he or she was presenting to the public.


There is no absolute obligation placed upon publishers to seek and obtain explanations from the plaintiff. The requisite extent of any prior inquiries will depend upon the nature of the source of information and the position, standing, character and opportunities of knowledge of the informant, as perceived by the defendant. Whether the defendant should have undertaken further inquiries should be determined only by reference to material properly available to him or her at the time of publication.


Generally it will not be reasonable to publish


(1) rumours that a person has been guilty of discreditable conduct;


() material known to be false, without an express disclaimer;


() an irrelevant defamatory statement in the course of giving information to those with the relevant interest; or


(4) unfair and inaccurate material.


Malice


For the purposes of the law of defamation "malice' is a particular state of mind, such as ill will or spite towards a plaintiff resulting in publication for an improper or foreign purpose or without an honest belief in the truth of the publication. These are separate and distinct grounds of malice. A belief in the truth of the publication is not sufficient, for example, to save a defence of qualified privilege where the defendant has published with an improper motive. The malice need not be directed at the plaintiff, so that malice in a publication directed towards the plaintiff or another person may defeat a defence of qualified privilege in respect of the defamation of the plaintiff by that publication.


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Our staff of freelance writers includes over 120 experts proficient in To Kill A Mockingbird, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your To Kill A Mockingbird paper at affordable prices ! Atticus says, " ……remember it is a sin to kill a


Mockingbird". I think the title Harper Lee chose "To Kill a


Mockingbird" is perfect for this novel. Both of these people are


very good examples of this motif. The injustice of Tom Robinson


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being accused of raping Mayella Ewell, and Boo Radely held


Prisoner in his own house since he was a little child. Tom


Robinson was simply convicted for being an African- American


and being at the wrong place at the wrong time. Boo Radely was


kept prisoner in his house because people thought he tried to kill


his mother and he was thought to be mentally ill.


Tom Robinson was accused of raping a white woman by the


name of Mayella Ewell. That's not the worse part, throughout the


trial they mention that Mayella was "mighty beat up on her right


side." Tom Robinson's right arm was disabled. When Tom


Robinson was a teenager he got his right hand caught in a cotton gin.


He can no longer use his right hand this is a very important


because that would mean that he could have to use his right hand


to beat her up on her left side to cause a black eye and cause many


more bruises. Boo Radley is held in his house because people


think he tried to kill his mother with a pair of scissors. To keep


him away from all the prejudice people his parents kept him


prisoner in his house till he was 6. He was innocent but people


were prejudice to him because he was mental ill.


On the day of the trial no one on the jury cared about the


facts. The jury took two hours to find this African-American man


guilty of a crime, which he was innocent of. The jury took a white


women's word over a black mans word. There was great sense of


pride that a white man would help defend an African- American


man in a trial. That is why at the end of court case, the African-


American community stood up as Atticus walked out of the court


room to show their respect and appreciation to Atticus. Boo


Radely is very similar to tom Robinson just because Boo is a little


different from everyone so people are prejudice against him.


Tom Robinson is shot seventeen times and killed, when he


tried to escape from prison. He was only shot to make and example


for he other inmates. Tom was a dead man because it was a black


man word against a white woman"s word. Tom Robinson and Boo


Radley are true "mockingbirds" they were both innocent. Tom was


still killed just for being at the wrong place at the wrong time. Boo


was miss treated because of what people thought of him Tom is a


true mockingbird and it was a sin to kill him because he was an


innocent man. Boo Radely was a true mocking bird and it was a


sin to keep him imprisoned in his on house for something he


didn't do.


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If you order your custom term paper from our custom writing service you will receive a perfectly written assignment on Desiderata. What we need from you is to provide us with your detailed paper instructions for our experienced writers to follow all of your specific writing requirements. Specify your order details, state the exact number of pages required and our custom writing professionals will deliver the best quality Desiderata paper right on time.


Our staff of freelance writers includes over 120 experts proficient in Desiderata, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your Desiderata paper at affordable prices with cheap essay writing service! After two centuries it is quite common for a literary works message to become outdated and forgotten. Few works can surpass the


longevity of Desiderata. Discovered carved into the wall of a church, its author has long been forgotten. However, his messages have


managed to pass the test of time. He states that people should not judge one another, because it causes vanity and bitterness. The author also


goes on to say we should be at peace with God. He acknowledges that we may all have a different god and that is ok. And lastly he tells us to


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pass by the noise and confusion of every day life and find peace and quiet. These lessons were all carved into a wall in the 1th century. Its


lessons on the danger of vanity, preservation of spirit, and value of silence still have their place in a 1st century society.


In todays society we judge we often judge one another. The author states, If you compare yourself with others, you may become vain and


bitter; for always there will be greater and lesser persons than yourself. When I see this I think of the underlying point; do not judge people. I


know I have judged people before on various things. I often judge peoples interests, style, intelligience, and personality. I know what I am is


pointless. However, in todays society is very hard to escape the pressures of placing people in different classes. I think that I do it because I


dont want to feel like just one of the crowd. I want people to see me and know I am different from the others. I also want that difference to be a


good one. This causes me to judge people harshly and put myself over them.


Religion is a heated topic. Everyone has their different beliefs. In our world today hatred and violence are often caused by differences in


religion. The author acknowledges that people have different gods when he says, Therfore be at peace with God,w hatever you conceive Him to


be. I take this to mean that people should have a personal relationship with their own god. A relationship that is not open to influence form other


people seeking power and wealth. I feel that there is a supreme being. However, I am not comfortable with having someone telling me how I


should show my loyalty to my God. I want a personal relationship with my God. This seperates me from historical religous prejudices and


corruption. My beliefs allow me to accept that others have different ideas on religion.


In the non-stop bustling world we live in today it is very hard to find time for peace and quiet. After school we go off with our friends, go to


the movies, parties, and concerts. We laugh, talk, and generally have a good time. However, I often wonder if we have lost touch with ourselves.


Can we no longer enjoy the simpler things in life. We have become fully accustomed to driving in the fast lane. I have always taken the time to


have peace and quiet. I feel I can work out my problems better when I am alone in quiet. I enjoy the time I spend in the peace and quiet because


know how rarely I get to escape the chaos of everyday life.


As I think about our world today I take note of the problems sorrounding me. One problem that has drastically effected my life and the life


of every American is September 11, 001. The world now is full of fear and hatred. Wars in the middle east wage on even though we say things


like major combat operations are over. People are still dying, and with every death more hatred is spread. If our anonymous author was alive to


day he could tell us how to stop this neverending cycle. Unfortunately he has passes, but he wrote it down before he did. The solution is scattered


throughout Desiderata. If society was able to stop judging people and remove the different castes we put people in it would help tremendously


in uniting the country. We need the country to come closer together. People no longer trust each other. Blacks and whites seperate themselves.


Arabs and pretty much everyone seperate themselves. We need to unite and heal our wounds together. Another problem in our world today is


the conlficts caused by religion. Muslims attack Jews in Isreal, and Jews attack Muslims in Palestine. Catholics and Protestants clash in Ireland.


It has been the cause of many wars throughout history, but it could have all been avoided. The author acknowledges that people may have their


own God. If everyone had a personal relationship with God than we would all be members of a different religion. We would not be subject to the


prejudices of todays churches. We would accept other peoples views and respect them for it. Furthermore, members of society should take the


time to escape it all and find peace and solitude. Get away from the noise and confusion and escape to solitude. There society could really


reflect on themselves. See what is wrong with them and think of solutions to their own problems. Society could be much better but it takes a little


time and effort.


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Introduction


If terrorist were to get hold of biological weapons and use them at the right time and in the right place, that could be the last day of your life on this world and the first of many horrible days for people in a different place of the world (Garrett 1). Hype pathetical scenario In February 1, the John Hopkins Center for Civilian Defense Studies mapped out a bioterrorist Scenario. In the scenario, the vice president of the United States makes a speech at a university. Eleven days later, a student with flu-like symptoms is admitted two the university hospital. Two days later the student comes back to the hospital fighting for her life. A janitor who cleaned up after the vice president's speech also turned up with the same symptoms . That same night the hospital's infectious disease expert comes to a disturbing conclusion that both patients have smallpox. This was a big surprise because the virus only exist in Atlanta and Siberia under lock and key, there can only be one conclusion someone had stolen one of these samples and used them as a threat directed at the vice president of the United States. Under this scenario more than 15,000 people die of smallpox worldwide within two months, and in about another 1 months 80 million people worldwide will be dead. Why people ask because all of the vaccines for smallpox was destroyed, and it will take years to make enough to help the world (JHCCDS 1).


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Background


Biological weapons- weapon used in which toxic biological agents are used to destroy, seriously injure or kill soldiers, civilians, plants, and animals (Encarta, Clark 1). Biological weapons cause civilian death and other problems when the agents drift into the air. Until the 0th century such weapons were limited to starting fires, poising wells, and distributing smallpox-infected articles (Encarta 1). Biological weapons have never been used on the battlefield, but the increased amount of research and testing of disease-producing bacteria caused worldwide alarm (Clark ). "As a result, the Biological Weapons Convention signed by the United States, the United Kingdom, the Soviet Union, and 67 other nations in 17 prohibited the development, production, and stockpiling of Biological agents and toxins (Clark )". Many people have asked the question is the United States prepared for a biological weapons attack by terrorist or another country?


Issue


The threat of America is changing. During the 170's and 80s, policymakers prepared for bombings and hijackings over seas. Today they are preparing to defend against attacks on the U.S. The worst of those threats is the use of a WMD (Weapon of Mass Destruction), more so the use of a biological weapon. The CDC is working to better the nation's capacity to respond to disease threats in the United States, including ones coming from bioterrorist. A strong and flexible public health system is the best defense against any disease out break. "In addition to working on our public health system, the CDC is exploring new approaches for the rapid identification of unusual events"(Terrorism Research Center 1).


Body


Smallpox and anthrax lead the list of biological weapons that could hurt the population. Anthrax struck with deadly effects in Florida, the small pox virus was basically over with in the late 170's. "But if smallpox was to ever make a come back, it would be far more difficult to contain". It's a less likely threat than anthrax, but potentially more catastrophic, because it is contagious. Smallpox was once a worldwide epidemic that was spread by coughing, sneezing, or physical contact( Boyle ). Anthrax which is not a contagious disease but is received by a break in the skin or mucous membrane. In recent years the public has become more aware of anthrax because of its development as a biological weapon( Compton's 1).


Causes


Anthrax, infectious disease caused by the spore-forming Bacillus anthracis. This disease usually occurs in warm blooded, domestic and wild animals, it also may occur in humans. The infection happens in one of three ways cutaneous, or through the skin; respiratory; and gastrointestinal. Humans get the disease because of exposure to infected animals or animal products. Anthrax lives in water, soil, and vegetation, and can be transmitted through the air. In the cutaneous form of the disease, spores enter the through a cut or a break in the skin. This form of the disease occurs mostly among people who handle contaminated wool, hides, leather, or hair products from infected animals. The gastrointestinal form of this disease occurs after eating contaminated meat. The most deadly form of anthrax is the respiratory. This has been call the "wool sorter's disease" because it occurs most commonly with people who work with such animal products wool, hides, leather, and hair -particularly goat hair. This disease transmitted by inhalation of spores containing dust from these items( Compton's 1 and ).


The next smallpox epidemic would be the release of the disease on purpose. No other agent has a high death rate as smallpox that's why a terrorist would use it. Since smallpox ability to spread from person to person is easy then that makes it a more of an ideal weapon to use. Also there is no real treatment for smallpox, and also the one vaccine that works to help calm the symptoms is only in a limited supply. "Although smallpox has always been feared universally as the most devastating of all infectious diseases, its destructive potential today is far greater than at any time in history"( Henderson 1).


Symptoms


In the cutaneous form of anthrax the first sign is usually a raised itchy bump. Then within a few days the bump develops a black center, which is dying tissue. Then the infection may spread into the blood stream. 0 percent of these cases untreated result in death. In The gastrointestinal form of anthrax the first sign is inflammation of the intestinal tract. Next pain in the abdomen, vomiting blood, and diarrhea. About 0 to 60 percent die. In the respiratory form of anthrax symptoms are usually those of a common cold. In a few days the spores reach the chest cavity that contains the heart and bleeding and inflammation occurs. From the chest cavity, the spores easily enter the bloodstream, resulting in shock( Compton"s 1 and ).


The first sign of smallpox is a fever that begins 7-1 days after infection. Second, sign is pimples 1-5 days after fever. Third, sign is blisters or pustules 1-4 days after the pimples. Fourth, scabbing occurs -6 days after the blisters. Fifth, the scabs fall off with in 10-40 days after beginning eruption, which leave pink sores, which become white after months (Henderson 1)


Treatments With anthrax in countries where the disease level is high, humans should avoid contact with livestock and livestock products and avoid consuming meat the meat that has not been cooked right. Treatment with antibiotics must begin before the symptoms start. Penicillin is the most commonly used treatment. There also several other antibiotics that are just as effective( Compton's 1 and ).


The Vaccinia virus is a very effective agent against the smallpox virus. The use of the smallpox vaccine has diminished smallpox greatly. At the World Health Organization in 180 smallpox the world was declared smallpox free. The smallpox vaccine is now only given to laboratory workers that work directly with smallpox( CDC 1).


Conclusion


The major question people asked was is the world prepared for a biological weapons attack on the U.S.? The CDC has is building up the dormant stocks to be used. This stock will only vaccinate 7.5 million of the 15.4 million people in the United States. The CDC has also ordered 40 million doses of a new vaccine from a company in Britain. This stock of medicine wont be ready until 004( Boyle ). On the other hand anthrax most recent antibiotic Cipro is being made in laboratories and has been very effective when given to the person in enough time( Boyle ).


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Our staff of freelance writers includes over 120 experts proficient in eropean union, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your eropean union paper at affordable prices ! September 11, 001 has opened the world up. The events of September, 11 have demonstrated that terrorism can affect, in its most horrific and inhuman form any part of the world at any time and no one can feel safe unless this civilization-eating monster is completely eradicated from our planet. The European reaction to the events of September 11 was a) to sympathise with the United States; b) to declare that the Member States were willing to support the action each according to its means; c) to insist on the need to avoid impulsive and hasty responses; and d) to step up its involvement in anti-terrorist action. Consequently, the EUs task was to provide citizens with a high level of safety within an area of freedom, security and justice by developing common action among the Member States. Thereby, on 7 December 001, the Council of the European Union adopted four Acts by written procedure. These measures were simply circulated to EU governments and adopted unless any objections are raised on terrorism. None of them were subject to any form of democratic scrutiny, at least at the EU level, before adoption and in part these measures also circumvent democratic scrutiny over other proposals. Moreover, these legal documents significantly lack human rights component as it is spelt in international human rights and particularly refugee law. Also, to a large extent, the application of these measures is not legally accountable either. In the present article, I intend to test the adequacy of EU policy responses to the terrorist threat and the extent to which these measures are applicable and justifiable within the meaning of international law.


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IntroductionSeptember 11, 001 has opened the world up. Dramatic as this sounds it is a fact. This is the day when the world realised the true cost of terrorism. However, this was not the day that terrorism was born, terrorism has been in existence for many decades, if not hundreds of years, and it has been tolerated or, even seeded, as long. The events of September, 11 showed that terrorism can shown up in its most horrific and inhuman form in any part of the world at any time and no one can feel safe unless this civilization-eating monster is completely eradicated from Earth. Immediately after that, US President Bush launched a war against terror and called on Europe to face the truth about terrorism and support the US in the war against it. In turn, the European reaction to the events of September 11 was a) to sympathise with the United States; b) to declare that the Member States were willing to support the action each according to its means; c) to insist on the need to avoid impulsive and hasty responses; and d) to step up its involvement in anti-terrorist action. States are particularly sensitive to either outside or inside influences and responsive to apply the mechanisms of state regulation to eliminate undesirable intervention into the status quo in the areas falling within their competence. It is, therefore, not surprising that that state sensitivity is more likely to be affected when and if there is a serious threat to stability and sustainability of countrys political and social welfare. It is a sense of threat that mobilises political activity and initiative that later turn to policy development and formulation. The perceived threat may become an important detonator to the creation and transformation of migration and asylum policies and the formula threat-challenge-response has been an actual vehicle for policy-making and implementation for many years. In turn, states are supposed to act in the interest of the majority of people and guarantee effectiveness and adequacy of public awareness and policy responses. The threats might be, of course, illusive and exaggerated, but nevertheless they render a solid ground for governments to react and take assumedly appropriate measures. Not surprisingly, the EUs, as a union of states, objective is to provide citizens with a high level of safety within an area of freedom, security and justice by developing common action among the Member States. Thereby, on 7 December 001, the Council of the European Union adopted four Acts by written procedure i) Common position on combating terrorism, ii) Common position on the application of specific measures to combat terrorism, iii) Regulation on specific restrictive measures directed against certain persons and Entities, iv) Implementing Decision establishing the list provided for in Article () of the Council Regulation. These measures were simply circulated to EU governments and adopted unless any objections are raised on terrorism. None of them were subject to any form of democratic scrutiny, at least at the EU level, before adoption and in part these measures also circumvent democratic scrutiny over other proposals. These legal documents significantly lack human rights component as it is spelt in international human rights and particularly refugee law. Also, to a large extent, the application of these measures is not legally accountable either. Below, I intend to test the adequacy of EU policy responses to the possible terrorist threat and the extent to which these measures are applicable and justifiable in the European context of international law. I. General observations1. Lack of legal interpretation The Treaty of Amsterdam has inserted a specific reference to the fight against terrorism into Article of the EU Treaty (ex Article K.1), thereby allowing the Member States to adopt common positions, decisions, framework decisions and conventions in order to establish closer co-ordination in this field. It also assigned the task of co-ordinating the fight against terrorism to the European Police Office (Europol). With the relevant European Convention having come into force on 1 October 18, police co-operation on terrorism under the auspices of Europol began on 1 January 1. Furthermore, the European Council reached political agreement, subject to parliamentary scrutiny reservations by three delegations, on the Framework Agreement on combating terrorism at the EU Justice and Home Affairs Council on 7 December 001. The Framework Decision defines terrorist aims and offences and establishes thresholds for minimum/maximum penalties for various types of offence. When defining terrorist aims, the Council opted for a wording that strikes a balance between the need to punish terrorist offences effectively and the need to guarantee fundamental rights and freedoms, ensuring that the scope could not in any circumstances be extended to legitimate activities. Now, it should be observed that none of the four measures adopted on December 7th was the proposed Framework Decision harmonising national law on terrorism, which was the subject of the above political agreement. The first two of the four measures were Common Positions based on both Articles 15 and 4 of the EU Treaty. Article 15 provides that the Council shall adopt common positions Member States will ensure that their national policies conform to the common positions. At the same time, Article 4 stipulates respectively that in the areas referred to in this Title, Member States shall inform and consult one another within the Council with a view to co-ordinating their action. This all means that these measures address matters both within the scope of the Common Foreign and Security Policy (CFSP) and within the field of Co-operation in Justice and Home Affairs (CJHA). Further, the Council Common Position on combating terrorism, is based largely on the UN Security Council Resolution 17 of 8 September 001, which was passed on 8 September in the immediate aftermath of the 11 September attacks on the USA. There are however very significant differences worth to mention here. Point (a) of the Security Council Resolution says that states shall refrain from providing any form of support, active or passive, to entities or persons involved in terrorist acts, including by suppressing recruitment of members of terrorist groups and eliminating the supply of weapons to terrorists. Article 4 of the EUs Common Position is instead worded to require Member States to prevent the public from offering any form of support, active or passive to such persons or entities. The change of meaning by the EU fails to distinguish between individuals who consciously assist those involved in terrorist acts and those who simply share the same goals as the terrorists but who do not pursue these goals by violent means or knowingly assist with the preparation of violent acts. Nor does this EU definition distinguish between support for terrorist groups and liberation movements, as does the Statement attached to the proposed EU Framework Decision on harmonising national laws on terrorism agreed by the Justice and Home Affairs Council on 6-7 December.. Refugees and asylum-seekers in the context of anti-terrorism measuresThe 1 men, who hijacked the planes that crashed into the World Trade centre and Pentagon, killing more than 6,000 people, were foreigners who had been in the US from a week to several years. Now, as a matter of fact, there is not a single EU member state that has not been affected by migratory movements. The continents strong economies and liberal democracies have been attracting increasing numbers of economic migrants and people in need of protection. For instance, in 18, of the EUs 74 million people, 1 million were immigrants, of which 1 million were from outside the Union. At present, these numbers are steadily high. Immigration and asylum were, therefore, perceived by public and authority as an advantageous loophole for potential terrorists or their associates to cross illegally the Unions external border and to assume their criminal activity. One of the EU serious concerns became that European States and the US should tighten their border controls following the attack on September 11 to protect its territory from terrorists. Consequently, then there arises a significant point of consideration. Whatever approach is taken towards refugees and asylum seekers, in my view, it is necessary to ensure that this category of vulnerable people do not become victims of recent events. All persons requesting asylum should therefore be granted access to a procedure in the EU Member State. In order to implement the 151 Refugee Convention in good faith, it is essential to determine whether an applicant fulfils the requirements of the Convention. Automatic bars to consideration of asylum claims, even of suspected criminals, are thus not in conformity with the Refugee Convention. In addition, because exclusion from refugee status may have potentially life-threatening consequences, such decisions should be made within the asylum procedure, by an authority with expertise and training in refugee law and status determination. Undoubtedly, it is equally important to ensure that criminals committing or planning serious crimes, such as terrorists, do not take advantage of the refugee protection system. Member States have a responsibility to implement the exclusion clauses of the Geneva Convention rigorously to fight such abuses. Indeed, the exclusion clauses contained in Article 1(f) of the Refugee Convention not only permit, but clearly oblige the contracting states to exclude certain categories of individuals from protection as refugees. The rationale underlying the exclusion provisions is that certain acts are so grave as to render their perpetrators undeserving of protection as refugees, and the receiving country must be protected from persons who present a danger to public safety or national security. In line with UN Security Council Resolution 17 and in accordance with international refugee case law, exclusion of persons involved in terrorist acts from refugee status may be based on either of the three grounds listed in the exclusion clause of Article 1(F), depending on the circumstances of the case. The last seven points in the EUs Common Position, Article 11 to 17, are not binding in the UN Security Council Resolution, but there are in the former. Article 16 saysAppropriate measures shall be taken in accordance with the relevant provisions of national and international law, including international standards on human rights, before granting refugee status, for the purpose of ensuring that the asylum-seeker has not planned, facilitated or participated in the commission of terrorist acts. The Council notes the Commissions intention to put forward proposals in this area, where appropriate under EU law this Common Position is binding on all Member States and will mean that all asylum-seekers and refugees are subject to vetting by the police and security services before their status can be granted. In effect a file will have to be created on each person/family as to their political and trade union activity in their country of origin or any other country they have stayed in. And, certainly in the new UK Anti-Terrorism, Crime and Security Act, they would never know what intelligence or suspicions had been recorded against them. This provision, taken in conjunction with Article 4 of the EU Common Position covering any form of support, active or passive for terrorist activities, could mean that a person who had helped raise funds to support the humanitarian needs of , say PKK prisoners in Turkish jails, could be refused refugee status. This is a gray area in the European asylum and migration policy, which according to Article 18 of the Charter of Fundamental Rights is at least party a human rights policy and should contain elements far more favorable for those affected than is the case under the national political process. Moreover, the interface of surveillance and intelligence-gathering to combat terrorism and illegal immigration can easily be combined. At the end of December the UK placed undercover MI6 Asian operatives inside the Sangate detention center in northern France. The MI6 (the UKs external intelligence service) operatives were supported by a team of 5 Special Branch officers providing logistical and intelligence support. The Special Branch is comprised of specially trained police officers who work in plainclothes, are proficient in at least one foreign language and who monitor the activities of specific foreign national or ethnic groups resident in the UK. The principal caveat here is that the matter of asylum should not be tied with, perhaps, legitimate and justified restrictive approaches against illegal migrants. It is true that immigration and asylum polices have become increasingly interdependent and incorporated plenty of issues similarly important for both areas. But improving effectiveness and operational capacities in dealing with refugees and immigrants does not necessarily mean developing capacities to stem illegal migration and vice versa. These objectives are even intentionally placed under different pillars of Community law. My overall argument is that asylum questions should be dealt within the context of freedom of movement of persons, not as a means to sustain the border control and fight terrorism. After all, the tightening of the border control and asylum regime undermines the concept of free movement as such, which is premised on the hob of the free market ideology of the EU. In the event, it is incompatible with the supreme goals of the Union. Summing up this point, I would like to share the AGIT Groups point of view forwarding that the starting point for EU policy on immigration has to be based on a positive view of immigration, against which any restrictions must be justified. The actions taken against illegal migrants and terrorists should not affect movement of potential vulnerable refugees. . Absence of legal and democratic scrutinyA standard reproach concerning the EU legal and democratic supervision is that the scrutiny is insufficient. Democratic deficit has always existed in the EU, especially prominent after the Single European Act (SEA) in the mid-180s. In a narrow sense, the democratic deficit is the gap between the powers of the European Parliament and EUs executive bodies. It was accentuated by the SEA and subsequent treaty changes that transferred responsibility for a wide range of policy areas from the national to the EU level of government. Before such large-scale transfers, national parliaments had the legislative authority to enact laws in the policy areas concerned. At the EU level, the European Parliament shares legislative authority with the Commission and, primarily, the Council. European rules are often held to be excessively detailed and in some cases appear to neglect national practices and the specific way in which each Member State carries out certain policies. As such, they run counter to traditions and identities, i.e. the way in which the peoples of Europe have built up their nations over the centuries. Moreover, they do not take account per se of the distribution of powers which certain Member States have introduced between the national level and the regions, particularly the regions which have legislative powers. The matter of powers emphasises certain shortcomings in the way the Union operates- lack of clarity, stemming from the complexity of the procedures and the number of instruments; - lack of accountability when the decision-making process is obscured by complexity, when those whom the citizens can sanction are not always those who take the decisions or are reluctant to shoulder their share of responsibility before the people who voted them in, democracy is ill-served; - lack of proximity, stemming from the fact that the principle of subsidiarity is not always respected; - lack of effectiveness protracted decision making, what Europe does being not in line with the main expectations of its citizens. Clarity, accountability, proximity, effectiveness there is no questioning the objectives, but how to attain them needs to be examined carefully. The adoption of the two Common Positions by the Council of the European Union (the 15 EU governments) by written procedure were made under Article 15 of the Treaty on European Union, which gives a very general power simply to adopt common positions and Member States shall ensure that their national policies conform to the common positions. Common Positions are thus binding on all EU Member States, but do not have to be submitted to national or European parliaments for scrutiny, they are simply adopted. In these two instances the measures adopted cover both Common Foreign and Security Policy (CFSP) and third pillar issues on police and criminal cooperation (Title VI of the TEU) and the European Communitys migration and asylum policy (Title IV of the ECT). By choosing to adopt these measures as Common Positions, the Council has not only by-passed the European Parliament, it also means that their validity cannot be challenged before the Court of Justice.As European leaders struggle to sell the concept of European integration to their citizens, they handicap themselves by failing to provide effective channels of accountability, and by perpetuating the democratic deficit. Changes made as a result of amendments by treaties of Maastricht and Amsterdam should have make Europe more real to its citizens. The democratic deficit can only be addressed by a wholesale reform of the EU institutions aimed at making them accountable to the citizens of Europe instead of to the leaders of the member states. II. Legal appraisal 1. Common Position 001/0 This is clearly based very closely on Security Council Resolution 17 (001), which, as mentioned earlier, was adopted shortly after the attacks on the USA (8 September). In fact, Articles 1 to 15 of this Common Position correspond in turn to points 1(b) to (d), (a) to (g) and (a) to (e) of the Security Council Resolution.However there are certain differences between the Resolution and the Common Position. They are as followsa) the last seven points, in Articles 11 to 17 of the Common Position, were not binding obligations in the Security Council Resolution; the Security Council merely call[ed] upon states to take the relevant measures.b) in point 1(d) of the Resolution, states were required to prevent their nationals and entities within their jurisdiction from providing funds to terrorists. However, Article of the Common Position appears to impose a total prohibition of any funds to such persons. It is questionable whether the Council can impose prohibitions outside Member States jurisdiction.c) in point (a) of the Resolution, states were obliged to refrain from supporting entities or persons involved in terrorist acts. Article 4 of the Common Position as worded instead requires Member States to prevent the public from offering any form of support, active or passive, to such persons or entities. This change to the meaning of the Resolution is questionable in the absence of any clarification of such a prohibition, to distinguish between individuals who knowingly assist those involved in terrorist acts with their plans and those who merely share the same goals as the terrorists, but do not pursue those goals by violent means or knowingly assist with the preparation of violent acts.Also, parts of this Common Position are potentially questionable from a legal point of view. Articles 10, 16 and 17 deal with subjects which form part of the European Communitys migration and asylum policy. As such it is doubtful that the EU can adopt a foreign policy measure affecting these subjects, thereby circumventing the European Parliament and the European Court of Justice. Similarly, points 1, 5, 8, and 11 deal with police and criminal law issues. These points, particularly point 1, arguably go beyond the powers conferred on the Council by the EU Treaty when it adopts a third pillar Common Position, since the Treaty implies that third pillar Common Positions are not binding and also makes clear that the Council must adopt a framework decision if it wishes to harmonise national law. In this case the Council purports to bind Member States and to harmonise national law by use of a Common Position. Again there is a lack of judicial and democratic accountability, since (unlike other third pillar measures) the European Parliament does not have to be consulted on Common Positions, their validity cannot be challenged before the Court of Justice, and national courts cannot ask the European Court questions about their validity or interpretation.. Common Position 001/1 The second Common Position addresses the application of specific measures to combat terrorism. First of all, it defines terrorist act in several ways (Article 1()). This definition comes directly from the Councils political agreement of December 001 on the proposed framework decision on terrorism. More precisely, Article 1 of the agreed Framework Decision is repeated as Article 1()(i), (ii) and (iii)(a) to (i) of the Common Position; Article () of the Framework Decision is repeated as Article 1()(iii)(j) and (k) of the Common Position; and Article (1) of the Framework Decision is repeated as the final paragraph of Article 1() of the Common Position. Applying this definition, the Council decrees that the persons, groups and entities listed in the Annex to the Common Position are subject to certain restrictions. Article 4 of the Common Position states that Member States shall assist each other as regards criminal investigations, et al into all the persons and groups listed in the Annex. Articles and specify that further European Community acts will freeze the funds of, and block any resources going to, any of the international terrorist persons, groups or entities listed in the Annex. These Articles do not apply to the domestic groups listed in the Annex (for example, Basque organisations, organisations on opposite sides of the Northern Ireland dispute and listed ETA activists), apparently because the Council assumed that the EC did not have the power to freeze the funds of or block any resources going to those groups or persons. Again it is legally questionable whether the Council can use a Common Position to harmonise the criminal law of the Member States, and there is again a gap in judicial and democratic accountability because the Common Position cannot be challenged directly or even indirectly through the national courts by the persons, groups or entities named in the Annex and because there was no involvement of the European Parliament. In fact, it is particularly questionable that the Council used the mechanism of a Common Position to adopt a definition of terrorism that was (in the form of the Framework Decision) still under scrutiny in several national parliaments and subject to reconsultation in the European Parliament.There are also added human rights concerns with the Common Position. The draft Framework Decision on terrorism contains extensive references to human rights protection in its Article 1b, its preamble and in statements to be adopted by the Council when it is adopted. These provisions attempt to ensure that the definition of terrorism is not so broad as to endanger the protection of human rights. In contrast, while the Common Position takes over the definition of terrorism from the draft Framework Decision, it does not take over the provisions related to human rights. In fact, there is no reference at all in this Common Position to the principle that the definition of terrorism and the fight against it must be in accordance with human rights obligations.. Regulation 580/001 This Regulation, based on Articles 60, 01 and 08 EC, implements part of Common Position 001/1, setting out the details of the freezing of funds and the ban on the issue of resources to terrorist persons, groups or entities. As noted above, the Regulation only applies to international terrorism, apparently because of the belief that the EC lacks the legal powers to agree a Regulation concerning domestic terrorism. The Council has the power, acting unanimously, to adopt a list of persons, groups and entities to which the Regulation applies (Article ()). This Regulation is subject to possible rulings by the European Court of Justice on its interpretation or validity, but this prospect may be weakened, because of the Regulations connection with the Common Position. Also, the Council had to consult the European Parliament before adopting the Regulation, but it ignored the Parliaments views in several key respects, particularly as regards an expiry date for the application of the 4. Decision 001/7 This Decision implements Reg. 580/001 for the first time, listing the persons, groups or entities covered by the freezing of funds and the ban on the supply of resources. In fact, the list is the same as the list of international terrorist groups, persons and entities attached as the Annex to Common Position 001/1 . Again, while the Decision (along with any future amendments to it) is subject to the jurisdiction of the Court of Justice on its interpretation or validity, that power might be circumscribed by the existence of the Common Positions. Also, there was no involvement of the European Parliament in the adoption of the Decision, and there will likewise be no involvement in any later Decisions adding persons, groups or entities to this list.ConclusionDuring the year 001 terrorism has been confirmed as one of the major concerns for the European Union owing to its enormous impact on the European Union, the Member States, the economy and society. Existing groups continued their terrorist activities. The number of incidents showed a small decrease, whereas the scale of the attacks increased dramatically. Important from a global point of view is the fact that the European Union is not only a target for terrorist attacks but also an important area for preparatory and logistic purposes in the widest sense. In the aftermath of the 11 September attacks in the United States of America, it became clear that a number of the suicide hijackers allegedly prepared their activities in the European Union.It is more than obvious that all those circumstance lead to the effect that the governments of EU Members States have opted for a restrictive and consensual approach in their law and policies towards third-country nationals and currently, the forces pushing for exclusion have the upper hand, resulting in a multifaceted, very restrictive, exclusionary immigration and asylum regime in Europe. Such policies of exclusions intensified after September 11th are well visible by imposing by national governments visa requirements on the nationals of an increasing number of countries; imposing penalties on airline carriers carrying unauthorised migrants; sending asylum seekers back to first countries of asylum or safe third countries, without examining the merits of the asylum-seekers request; introducing asylum quotas; authorising law enforcement agencies to conduct random checks; applying strict criteria in determining whether an asylum-seeker is a genuine refugee; introducing a list of prosecution-free countries; and dealing with some types of asylum claims without respecting most of the fundamental procedural safeguards. Consequently, asylum-seekers travelling from or through states sharing borders with the EU are increasingly faced with a cordon sanitaire erected along the outer limits of the EU. The Vienna European Council acknowledges that the European Union is founded on principles of liberty, democracy, respect for human rights and fundamental freedoms and the rule of law. Protection of fundamental rights is a founding principle of the Union and an indispensable prerequisite for their legitimacy. Human rights provide a basis for the European legal order within and beyond the circle of the EU Member States. Although, the EU has not acceded to the European Convention on Human Rights and Fundamental Freedoms (ECHR), it is important to bear in mind that the ECHR is an international instrument, to which all European states have adhered, and proves to be a major instrument of European integration. The Unions institutions are required to respect fundamental rights, as guaranteed by the ECHR. EU leaders have been urged to stop paying lip service to the needs of refugees and asylum seekers. This call follows a conference on EU migration policies and comes amid growing concern that the Union member states will put up the shutters to immigrants in the wake of the current Afghanistan crisis. Much of the discussions in the EU have been about the impact any new security measures will have on immigration. However, deterring refugees leads only to the tragedy of human trafficking and countries distrusting and competing with each other. Immigration and refugee law and policy cannot not be purely restrictive as they should respect international obligations and humanitarian traditions, in general. Restrictions, if applied, should be consistent with the obligations of the national governments derived from the ECHR to guarantee protection, promotion and respect for human rights throughout the territory of Europe. While the terrorist attacks on the US were awful, they must not be allowed to dominate policy on immigration and asylum in Europe. This should be given top priority at the European level at all times.


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Our staff of freelance writers includes over 120 experts proficient in Emily Dickinson's poetry, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your Emily Dickinson's poetry paper at affordable prices with custom essay service! Emily Dickinson's poetry can be categorized as uniquely abstract. By her terminology, one can recognize contemplation patterns that are like no other. Dickinson grew up in a very privileged upper class home. From a visual aspect, it is very easy to assume that her life could not have been any easier since she never had to work for anything; but internally, there was a struggle that was present. Possibly as a result of negative personal experiences, her writing has come to have much significance. With the aid of her individual creativity, Dickinson was able to express her careless, opposing views on religion, and also her self-image.


Her free spirit expressively recognized God's existence, but refused to submit to his authority. She had established her own religion, and followed her own commands as clearly stated in 4. From her standpoint, God was simply overrated, and not a very good Father. At some point, through her various troubling experiences, she had been "led away" from him (poem 18). Set apart from others, death was clearly more favorable than eternal life from "an Eclipse."


Obviously, she had undergone a spiritual death. Revealing her insignificance towards her Omnipotent. The majority of the poems reviewed in class were based on her strong apathy towards this particular subject. Recognizing him as being there, but at the same time, not there. Possibly she saw earth as her heaven because of her love for nature. Heaven could of also meant being able to express herself through ink since she confined herself from the outside world, and it was also her only visual aid due to her poor eyesight.


Dickinson's self-image seemed to come strictly form within. In poem 45, she expressed her encounter with exclusion. Rejection is a very hurtful experience for any human being. In time, she realized that her mind was individual. She began to eventually come to terms with this notion, and accepted herself. Although, she was rather privileged in her up bringing, Dickinson chose to go in a different direction than others, and she chose to disconnected herself from the others.


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In her age, Dickinson was a very independent woman. In those days, independence was probably forbidden for a female. Her lack of commitment to the church was definitely some sort of struggle. Through her poetry, she spoke her true feelings to God, and also to the people that rejected her. The true reasons for her bitter feelings toward the higher power remain unknown. It has been left to our imagination to make of it what we want. Her poetry was her only way of communication to the world as she stated in poem 441.


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Our staff of freelance writers includes over 120 experts proficient in Jealousy, therefore you can rest assured that your assignment will be handled by only top rated specialists. Order your Jealousy paper at affordable prices ! Are jealousy and possessiveness linked to love naturally or does it have to do with our culture? Eighty percent of jealousy comes within each person; every human being has a little bit of this characteristic in his or her personality. Some people reflect it more than others do; some others let it rule his or her life. The fact or the matter is that all human beings are jealous, even God was a jealous person. Our own parents are definitely very jealous; so yes, we find jealousy commonly in our lives, but is it necessary to live surrounded by jealousy? The remaining twenty percent comes from our culture and the way we had been raised. Different cultures have other perceptions; for this reason, jealousy can be hidden, ignored or not experienced at all depending on the lifestyle of each individual.


Possessiveness and jealousy are unfortunately linked together. An individual who happens to be jealous becomes possessive. The idea of ownership of another human spirit goes against the principles of truth. Possession is a form of domination and control. The possessor manipulates others for his own purposes. When we truly love someone, we can never consider confining him or her to a cage. One who loves respects the uniqueness of the other. We must accept others exactly the way they are, without possessing, giving our partner the right of free will choice over his or her own actions. In mature relationships, individuals don not own each other!


In any relationship, one partner has had jealousy as an issue and the other member has not. This phenomenon happens due to the high level of insecurity within the relationship. These insecurities not necessarily were within us, but rather came form past experiences and from imagined fear of potential pain in this new relationship. Insecurities can arise from relationships that we have witnessed other than our own. When in any relationship jealousy reaches its peak point, it becomes suffocating due to the lack of freedom that is available. As human beings through years, we have been fighting for it. The worst thing that can be done to anyone is to try to take it away, so why put up with such miserable lifestyle?


As read in the play "Flight", being the perfect sample of excessive possessiveness. The grandfather thought he could keep something forever. He realized it absurd to force actions, it is better to let those actions flow naturally; get what is given, and never take anything forcefully. We cannot pretend that by trying to keep someone next to us we will get love in reward; love would be the last thing we will experience. After my lecture, I realized why we would want to own a person. Why want to have someone next to us obligated? The most beautiful thing in this world is to have that someone who loves us for who we are. Such person will stay next to us because of his or her own will, not obligated! Eventually she or he will stay because he/she is in love or simply loves us but soon this feeling will end because no one likes to feel trapped inside of someone else's mind. What I mean with this expression is that we cannot be under control; it is harmful to let one mind be on top of us constantly wanting to know everything. Jealousy will lead to a high level of possessiveness, and the above written is an example of it. When analyzing possessiveness we can get to the conclusion that this is no more than insecurity. When we feel insecure, we need to grab onto someone; however, this does not mean it will make our insecurities go away, we can become obsessive and this obsession can destroy our relationship.


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Trust is vital to love; it is the essential ingredient to have a healthy relationship, free of jealousy and insecurities. True love can never be taken it can only be given we never own another. Love and possessiveness are not linked to love naturally. It is more about our experiences, what we have lived through can rule in our future live.


The purpose of a relationship is to love and trust, trust and be trusted as well. As possessiveness can be corrosive for the heart, it can be devastating to relationships in general. When jealousy issues come up in our relationships it is necessary to take some time and determine the real issue. It is suggested to get clear about our feeling and then communicate them to our partner. This problem should be worked through until it is resolved. Any issue in a relationship is necessary to be talked about without judgment or blame.


Low self-esteem creates insecurity; jealousy, possessiveness, the need to be special, fear of abandonment, the need for a special partner to commit to us, need of a partner to commit to be with us only. The demon of possessiveness can be overcome through self- love. Our relationships with others can only be healthy if we are healthy we ourselves. Until we have our own healthy self how can we hope to co-create? If we love someone set them free, to be capable of this we have to love ourselves equally to first set ourselves free. "Love is the only thing that is real all else is just an illusion."


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Abenaki


Abenaki Indians were divided into groups the western and eastern Abenakis. Both have the same style of living. Abenaki originally from England moved to America when the French invaded their homelands. Although not recognized by the historian as a major Indian group, the Abenaki Indians were once a great tribe.


The family was the core of the Abenaki life. Abenaki family included mot only parents and children, as in a modern American family, but also grandparents, aunts, uncles, cousins, and in-laws. " Abenaki were affectionate parents"( Trigger 155). The member of a family usually lived together and sometimes under the same roof. An Abenaki boy was born into a world surrounded by relatives. Brothers, sisters, aunts, uncles, grandparents, cousins, and as well as parents all took a hand in the child's welfare and upbringing. When a mother went about her daily taks or worked in the fields with other women, she carried the baby with her in a cradleboard and hung it from a tree branch so the child could be close by and see all that was going on. Children took part in all aspects of family life and were expected to behave in a way that would be helpful to the others. Most importantly, young people were taught to respect their elders. The responsibilities of the men were hunting, fishing , warfare, and the fabrication of houses, canoes, and the implements of war and hunting. While the women's responsibilities were childcare, cooking, preparation skins and clothing, cultivation of agricultural crops, and gathering of food plants (Trigger 156).


An Abenaki warrior was responsible for the safety of his family, clan, and band. Farming wouldn't be possible if there was no defense against invaders. Therefore, defense was an important aspect's of a man's life. " To be a warrior meant that one could endure without complaint, all hardships of cold, hunger, pain, weariness. This was what young boys aspired to, and with the help of their maternal uncles, they were trained from an early age to shoot the longbow and wield the tomahawk, and knife" (Mehigan 1).


Joseph Bruchac is a modern Abenaki of Abenaki and European heritage. He writes poetry, fiction and some criticism literature. He has written many books especially for young readers. " In addition of being a popular writer, Bruchac is professional storyteller. He has made recordings of ancient stories so that can be enjoyed the way there intended to be by listening. Storytelling, he says, helps to keep us connected with the people of the past" (Gleason 7).


Abenaki was a really good tribe that wasn't recognized by most historians as a major Indian group. Abenaki were great people. One of the modern Abenakis is Joseph Bruchac who loves to write poetry. He made many children books about Indians. He does this so that people would learn about the way Indians lived.


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INTEREST RATE VOLATILITY DOES MATTER


The variability of interest rates directly influences how the public saves and invests, thus having a large impact on the standard of living. As fluctuations of the rate occurs, return on assets become less predictable forcing investors to re-evaluate their original investment decisions, or face the possibility of drastic loss. Those investors with low income are more likely to hold investments with relatively low volatility, ensuring a steady level of consumption. In contrast, investors with a steady level of income and a diverse portfolio can hold much more volatile investments. Any losses can easily be absorbed while holding the high risk/return investments.


Said volatility affects the business firm in a similar fashion as it does the investor. To manage risk firms must watch the changes in the interest rate in relation to the composition of their portfolios.


The Bank of Canada describes interest rates as "represent[ing] the cost of borrowing money over a period of time � the price that lenders charge borrowers for the use of the lenders money." As the rate fluctuates the amount of payment to the lenders varies therefore changing the total cost of borrowing by the public which, in a domino affect, affects their purchases, investing strategies and overall the health of the economy.


INTEREST RATES, BOND PRICES, AND THE TERM STRUCTURE


Typically, the price of a bond and the interest rate attached to it has a negative relationship. The term structure of interest rates is the relationship between the maturity of the bond and the interest rates implied by the bond prices. The yield curve, which is a graphical depiction of the relationship between interest rates and bond maturity, can take a variety of shapes because the U.S government offers securities with a variety of maturities. Usually interest rates on short term bonds are lower than interest rates on long term bonds which make the yield curve upward sloping. Based on the same logic, one might think that the volatility of interest rates varies with maturity. Since interest rates and bond prices have a defined relationship, when considering bond prices the interest rates can be found.


When considering a bond its clear whether it will fit into a conservative portfolio or a riskier one based on the derivation of its interest rate, the term structure is related basing the previous relationship to its maturity.


As seen in figure 1 the interest rates on the year bonds are constantly higher than those of the month bonds. The term structure of the interest rates is shown through the higher rate for long term bonds and lower rate for short term bonds. Based on the data, the longer the term to maturity the higher the rate will be. Since the price of the bond and the interest rate has a negative relationship, that prices of bonds between 1 and 00 would have been lower in the mid 10's and higher at the turn of the century.


Trends that are evident in the cycles of interest rates are long term variability is seen in long trends in interest rates. Short term variability fluctuates around these long term trends.


MEASURING THE VOLATILITY OF INTEREST RATES


Interest rate volatility is measured by a statistic called standard deviation, how dispersed a variable is around its average value. As the standard deviation increases it is probable there will be large changes in the value of the variable. The interest rate is the variable. A higher volatility is evidence of rates that jump far around the average and results in a higher standard deviation, thus standard deviation and volatility have a positive relationship. The correlation coefficient measures the strength of the co-variation between two variables, and can only be a number between negative one and one. If the correlation is close to positive one, the two variables are said to be moving in the same direction. If one is high so is the other. If the correlation is close to negative one, the two variables are said to be moving in opposite directions. If one is high the other is low. The correlation coefficient is useful in identifying the possible causes of interest rate fluctuations by plotting the interest rate directly against another variable to see if a relationship exists.


Based on previous data the following correlations are evident.


• Increases in current output are associated with increases in future interest rates.


• When current output rises the yield curve flattens. When output declines yield curve becomes steeper.


• Interest rates on bonds with different maturities are highly correlated with each other, specifically between bonds of similar maturity dates.


DETERMINANTS OF INTEREST RATE VOLATILITY


Determining short term interest rates. Current short term interest rates have a positive relationship with current output. If current output is low the current short term interest rates will fall at the same pace. The yield curve (interest rates vs. bond maturity) has the tendency to flatten when output is high and steepen when output is low. Such information derived from the slope of the yield curve does help to track and predict the different turns in the business cycle. For example, if the curve has a steeper shape, interest rates will be more varied signifying a change in the cycle, possibly the peak of an expansionary period. Expected inflation also determines short term interest rates. As inflation rises consumers expect a higher return from their investments, thus bond prices will fall and interest rates will rise. Since the direct relationship between inflation and interest rates, and determinate of inflation can be used in determining short term interest rates.


Determining long term interest rates. Long term rates are linked to short term rates. According to the expectations theory of the term structure long term interest rates are equal to an average of expected short term interest rates plus a risk premium. The expectations theory also links long term discount bond prices to expected short term discount bond prices over the life of the long term bond. Although like short term determinants, long term bond prices can be derived from include expected income growth and expected inflation; long term rates do not have a high co-variation with output.


Determining interest rate volatility. The economic variables that influence long and short term rates also affect the volatility of these rates- expected inflation and expected real income growth. Large changes in real expected real income growth are associated with large changes in interest rates. Large changes in expected inflation spark large changes in current bond prices and current interest rates, thus, the more volatile inflation is the more volatile bond prices and interest rates will be.


Inflation and income growth are factors that determine long term rates, short term rates and volatility, yet monetary policy is a factor that influences all of them. When the money supply grows to an excessive amount inflation is likely to be high. If monetary policies are volatile so is inflation. Its affect on real income is not as direct, only through certain circumstances of inflation leading to layoffs of workers could monetary policy affect the money supply.


Other factors that have an effect on interest rate volatility can vary from weather to changes in technology to a variety of economic models. These factors do not have a large effect and are only directly applicable in specific cases.


Economic models and interest rate volatility. One economic model suggests that investor's expectations of future real income growth and inflation are main determinants and interest rates.


Although economic models are useful in predicting some economic variables, when used as a tool in determining such a volatile variable such as interest rates, it may not be the most reliable. Predicting involves setting up identical economic circumstances within the model, but with the variety of factors on the economy, they are rarely identical.


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1.0 Introduction


Carry Churchill's Top Girls is an interesting play about how women have defined their roles in a male-dominated society. We are introduced to various women who have pursued their career at the expense of a personal life. The play begins with a dinner party at a restaurant among a group of women. What is notably interesting about this group of women is that they are from different time periods and culture. Churchill does not explain how these women from the past and present are able to converse with each other but the concept of this illogical scene is soon forgotten due to the wittiness and courage shown by all these women to overcome the hardship that they endured in a world ruled by men. The women are;


• Marlene A 0th century woman who has made a successful career for herself.


• Isabella Bird Lived around the 1th century and had traveled widely.


• Lady Nijo Lived around the 1th century. She was the Japanese Emperor's courtesan, who later in her life, became a Buddhist nun.


• Pope Joan Lived around the th century and disguised herself as a man. Later she became the Pope.


• Griselda Lived around the 1th century and is an obedient wife who's story is told in Chaucer's The Canterbury Tales.


• Gret She is the subject of the Brueghel painting in which a woman in an apron and armour leads a crowd of women charging through hell and fighting the devil.


In this essay, I am going to discuss how far women both in history and in the present modern world, have achieved happiness and freedom through their success in the male-dominated world. In order to make the discussion clearer, I have divided the essay into sections according to the characters in the play. Each character is discussed in detail to show to what extent these women have achieved happiness and freedom in their life. I have chosen to discuss six women in this essay. They are Marlene, Isabella, Lady Nijo, Pope Joan, Griselda and Louise, a woman who came to the employment agency to find a better job.


.0 Marlene


Marlene, who had just been promoted as a managing director in an employment agency, holds the dinner party that opens Act One. The scene starts with Marlene ordering a bottle of Frascati. Here, the readers are introduced to Marlene as a woman who wants to be served. The fact that she is ordering the waitress and making a decision not to wait for the others before placing the order, shows a very confident woman who knows what she wants .


Excellent, yes, table for six. One of them's going to be late


But we won't wait. I'd like a bottle of Frascati straight away


if you've got one really cold. (Churchill1)


I feel that Churchill has successfully established Marlene as a strong character from the beginning itself. Apart from that, Churchill had arranged the play in a way that the last act, Act Three, is actually set a year earlier, in Marlene's sister's kitchen. Perhaps, one can assume that the kitchen symbolizes Marlene who is supposed to be a mother or a wife but by putting the scene in the end, it could indicate that she had abandoned her duties as a mother/wife. Thus, the structure of putting the scene in the kitchen which is set a year earlier, in the end, while the scene of Marlene celebrating her career is put in the beginning to establish to the audience that Marlene is a career woman.


Marlene is also seen as a workaholic who wants to come up in the world of business, which is dominated by men. This is evident in the scene where Marlene seemed to be envious of Isabella who is able to travel around the world. Marlene is unable to do any traveling, as she is devoted to her work. It is obvious that Marlene puts a lot of effort into her career that she is willing to sacrifice the little pleasures of life such as taking a holiday, "I'd like to go somewhere exotic like you but I can't get away." (1) This shows that Marlene pushes herself to the limit to achieve success. The fact that Marlene, being a woman, needs to prove herself in the male-dominated business world by working hard, shows that not only is she determined, she is also sacrificing her happiness by putting all her efforts in her career. Other than that, it has been years since she has been to church. This shows that religion takes a back step when one is busy advancing one's career. Marlene's attitude is more like a man than a woman. What is interesting to note here is that when the conversation steered towards clothes, Marlene insisted that she does not wear trousers to work even though she could wear it, "I don't wear trousers in the office. I could but I don't." (8) It is as if Marlene is self-conscious of being labeled a man. By choosing not to wear trousers, Marlene seems to insists that she is still retaining her feminine side.


Marlene does not have a man in her life. Perhaps this indicates she does not want to be burdened by wifely duties. Marlene wants to be independent. As an individual, Marlene does not have to explain her actions to anyone and is not tied down. Thus, she has the freedom to do what she wants. At one part of the conversation, Pope Joan talked about feeling ill and regret after being made a cardinal. To that Marlene commented, "yes, success is very…" (1). She did not complete her sentence. Did she want to say that success is very fulfilling or just the opposite? Were all her sacrifices worth the success that she is enjoying now? Perhaps this gives a hint that Marlene is slightly disappointed with her life. She may be very successful in her career but she has no one to go back to when she goes home. There is no family to greet her when she goes back home or to show her love. Although one can assume that her unfinished sentence could indicate a tone of regret, Churchill quickly establishes that Marlene is against having a family. This is indicated when Pope Joan mentioned about her baby and Marlene's immediate question was, "Didn't you think of getting rid of it?"(15) Marlene's callousness is evident here. Marlene sees children as inconvenience. She sees babies as barriers, an obstruction to become successful. This is further seen when Marlene was interviewing Jeanine, a girl who wants to look for another job with better prospects, Marlene asked Jeanine not to mention the fact that she was going to get married, during her job interview.


Marlene So, you won't tell them you're getting married?


Jeanine Had I better not?


Marlene It would probably help / There's no need to mention


it when you go for an interview. (1)


Perhaps, Marlene feels that a married woman would not succeed in securing a good job. This could be because married women would have to take maternity leave and this would not be in favour of the employer. This would definitely affect their performance at work. This could explain why Marlene herself is not married. She even had two abortions, "I've had two abortions/it wasn't a problem/I don't want a baby."(81) Marlene was not willing to keep any of her babies because she does not want any family responsibilities to get in the way of her career.


All the efforts and energy that Marlene put into her work, finally paid off when she was made the managing director of her agency. She was picked over another male for the post. It is a post that Marlene deserves as she worked hard and sacrificed a lot to reach that position. This is supported by her colleagues who felt that Marlene deserved the post compared to Howard Kidd, a male worker.


Howard thinks because he's a fella the job was his as of right.


Our Marlene's got more balls than Howard and that's that. (46)


Although Marlene is a woman, it is clear that Marlene is better than Howard in her job. Howard could not accept the fact that he lost the post of managing director to a woman. He fell sick due to this. Perhaps Howard felt that it would be a disgrace to take orders from a woman. This is confirmed when Howard's wife comes to see Marlene and asks her to give up her job to him.


What's it going to do to him working for a woman? I think if it


was a man he'd get over it as something normal.-/ It had crossed


my mind if you were unavailable after all for some reason, he


would be the natural second choice I think, don't you? I'm


not asking. (58-5)


It is as if Howard's wife is threatening Marlene to give up her job as she mentioned in the end that she was not asking. She was probably ordering Marlene to step down as it would be a disgrace for her husband to work under a woman. She even goes on to accuse Marlene of not being sympathetic and cursed Marlene that she would have a miserable life, "You'll end up miserable and lonely. You're not natural" (5). Mrs. Howard feels that a woman should not be more successful than a man. That could be the reason why she felt that Marlene was not natural. Just like what Mrs. Howard said, Marlene is living a lonely life. Could she truly find happiness by only having a successful career?


There is also competition among the female workers for a higher position. This is evident when Marlene asked Nell if she felt bad because Marlene got the promotion instead of her to which Nell answered, "I don't like coming second" (50). The competition among them resembles a male power structure. In addition, the language used by these working women when talking among themselves, such as "more balls", "nerd" and "little bugger", indicates that they have even adopted the style of speech that is commonly used by males. Do women have to be like men in terms of character and attitude in order to compete with them? Do women also become the oppressor when they have become successful?


Success has made Marlene to become a very harsh person. She commented to one of her friends that Angie, her own daughter, would not be successful in life. She stated that Angie would most probably end up being a packer at Tesco. She even went on to call her stupid, "She's a bit thick. She's a bit funny/She's not going to make it" (66). Apart from that, in a conversation with her sister, Joyce, Marlene suggested that Joyce could have left their place like she did, to which Joyce asked, "How could I have left?/I said how could I?" (76). Unlike Marlene who ran away from her responsibilities as a mother and daughter, Joyce thought about taking care of their own mother, her husband and the daughter that Marlene had abandoned to pursue her career. Marlene got pregnant when she was seventeen and left her baby in the care of Joyce. She knew that a baby would only be in the way of pursuing a career for herself. In order to have a successful career, Marlene had become harsh and selfish. She is not bothered about other people and feels ashamed to be associated with the working class. This is supported by Joyce's statement accusing Marlene of being ashamed of her own sister.


….you're ashamed of me if I came to your office, your smart


friends, wouldn't you, I'm ashamed of you, think of nothing


but yourself. (85)


In her pursuit of a career, Marlene had become hard on the inside. Perhaps Marlene sees emotional attachment as a weakness. Marlene also believes that only those who work hard will succeed.


Anyone can do anything if they've got what it takes/If they're


stupid or lazy or frightened, I'm not going to help them get


a job, why should I? (86)


Here, Marlene's selfishness and individualism comes across. Success has made Marlene to look down on other people. She is tough and thinks that anybody else, who is not strong enough, does not fit to be in the working class world. She has become just like a man. She has become the oppressor.


Has success brought freedom to Marlene? Yes, she does have freedom to do what she wants but what about happiness? Marlene is so busy trying to get ahead of her career that she has no time to take a vacation or go out with men. She has to give away her own daughter. She has no one to go back to at the end of the day. She has no family. She has no one to love her. Marlene may be successful in her career but in life, she is one lonely woman.


.0 Isabella


Isabella Bird is a traveler who lived around the 1th century. She is a person who cannot sit still. She is always traveling. During her travels, Isabella mentioned that she did miss her sister, Hennie, but she did not go back as she is not suited for the quiet life that her sister enjoys. The fact that Isabella had met the Emperor of Morocco shows that she has traveled wide. Isabella is a very independent woman. She did not get married until the age of fifty, "And I didn't get married till I was fifty" (). This shows that she is able to live without a man for a long time. Her marriage does show that for all her independence, Isabella still needed a man in her life. However, Isabella did not marry because she loved he husband, rather it was the dedication and compassion he showed towards her sister when Hennie was ill, that made her marry him.


It was Doctor Bishop's devotion to her in her last illness that


made me decide to marry him. He and Hennie had the same


sweet character. I had not. (11)


Isabella did not marry so that her husband can protect her. Perhaps she married him hoping that his good character would influence her and do her some good as she stated that she did not have his "sweet character".


She is also a very knowledgeable person. Even though Isabella lived around the 1th century, her father taught her Latin although she was a girl. This shows that her father wanted her to be educated. This could explain why she is not like many of her other contemporary woman who are uneducated and sit in the house. However, Isabella claims that she is more suited for domestic work.


My father taught me Latin although I was a girl/ But really I


was more suited to manual work. Cooking, washing, mending,


riding horses. (-4)


This seems to be in contradicting to her character that is not able to stay in a place for long. Perhaps if Isabella did get married at a young age, she would probably make someone a good wife.


Through the character of Isabella, Churchill brings across the idea of feminine in a man's world. Although Isabella travels widely and is independent, she insists that she is still a feminine.


Well, I always traveled as a lady and I repudiated strongly any


suggestion in the press that I was other than feminine. (8)


By stating that she travels like a lady, Isabella comes across as a strong character as she is not afraid to travel as a lone woman. She is also proud being a woman. This shows that Isabella has a lot of freedom in a male-dominated society.


When her husband died, she did not give up hope. This shows she has a lot of courage and determination as she was already fifty-six years old at that time, "I detemined to leave my grief behind and set off for Tibet"(1). The fact that she decided to go to Tibet shows that she is a woman who takes control of her own life. Furthermore, evidence of her tough character clearly comes across when she goes mountain-climbing with a group of people. She proved that a woman can be better than a man when she managed to finish the climb.


We were crossing a mountain pass at seven thousand feet, the


cook was all to pieces, the muleteers suffered fever and snow


blindness. But even though my spine was agony I managed very


well. (1)


Isabella had proved that women are not weak and sensitive. They can be brave and tough and should be treated with respect.


Similar to Marlene, Isabella leads a lonely life. After her husband died, she did not remarry or have any close relationships with men. Her only companion seemed to be a horse named Birdie.


I never had any children. I was very fond of horses/ Birdie was


my favourite. (18)


She described her favourite horse in a very loving manner as if she was describing a child. Perhaps there is a hint of sadness here as like Marlene, Isabella does not have a family to go to. This could explain why she got actively involved in community work. She needed to occupy herself, something to keep her busy so that she would not be lonely.


Isabella has been successful in her own right where she has proved herself to be worthy in a male-dominated society. She has not only traveled the world on her own but she has proved that for a woman, she is as capable as a man. However, her interest in traveling and the idea of independence had eluded her from having any serious relationship with men. Thus, could Isabella truly be happy with the life she has chosen? Perhaps her active involvement in community work gives a clue of her unhappiness and her feelings of not wanting to be lonely.


4.0 Lady Nijo


Nijo is the Japan's Emperor's concubine who lived in the 1th century. She became his concubine at the age of 14 . When Marlene asked if she was raped by the emperor, Nijo denied it and defended the emperor's act by saying that it was her duty to serve him.


I belonged to him, it was what I was brought up from a baby. I


soon found I was sad if he stayed away. It was depressing day


after day not knowing when he would come. ()


Nijo needed the emperor. She wanted to be with him. Since small, Nijo had been told that she was to serve the Emperor. Thus, without the Emperor, Nijo feels incomplete. The Emperor made her happy as she did not fell lonely.


Nijo is portrayed as a dutiful daughter. She became a nun because that is what her father wanted if she could not make the emperor happy anymore.


Serve His Majesty, be respectful, if you lose his favour


enter holy orders. ()


Nijo did as her father asked. Nijo admits that half of her life was spent in a sinful manner by serving the Emperor while the rest of it was spent looking for atonement for her sins (5). When Pope Joan asked her which life she liked best, she answered "repentance'. She found happiness in her later life. Perhaps Nijo felt guilty that all this while she not only led a life of sin but also a life of comfort. While serving the emperor, she enjoyed being lavished in good clothes. This is evident by her comment, "What I enjoyed most was being the Emperor's favourite/and wearing think silk" (4). Here Nijo shows her feminine side. Unlike Isabella, Nijo prefers to stay at home and serve the emperor. She liked the comfortable life. The only time she showed any defiant towards the emperor was when she hit him with a stick in protest of her and the other courtesans' treatment by the emperor's servants. This is the only time we see Nijo going against the norm. As a woman in the 1th century, Nijo showed a lot of courage by hitting the emperor.


Afterwards, there was a terrible fuss. The nobles were horrified.


"We wouldn't even dream of stepping on your Majesty's Shadow'.


And I had hit him with a stick. Yes, I hit him with a stick.(7)


However, this success that Nijo enjoyed in the male-dominated society may actually hinder the freedom of other women of similar position to Nijo. According to Jones in his article, Gender Roles in Churchill's Top Girls,


Nijo attacking her Emperor is likely to have caused the Emperor


to restrict significantly the liberty of his concubines, the liberty


that Nijo enjoyed. In this way, future women are prevented from


achieving what Joan and Nijo do. (1)


Thus, Nijo's defiant act could actually result in less freedom for future concubines of the Emperor. On the other hand, Nijo's action could be seen as the opening all the other women need to get men to teat them with respect. Nijo had set and example for all the other woman to fight for their rights and to be taken seriously.


It is interesting to note that most of Churchill's women characters gave up their babies. Marlene gave up her baby so that she could get a career and make something out of herself. Griselda gave up her babies as a sign of love and devotion to her husband. Nijo gave up her babies to be in favour of the Emperor and lead a comfortable life as the emperor's concubine. Nijo became pregnant with her lover's child and had to give up the baby in order to be in the favour of the emperor. Subsequently, Nijo gave up all her three babies as she was afraid the Emperor would punish her as the babies were not his. Here, we can see that Nijo has no freedom to do what she wants in her life. Nijo cannot be truly happy with her life as she had to give up her children. When the group of women was talking about Griselda getting back her children, Nijo commented that she did not get her children back and she started crying (5). Nijo may have been successful in being the best concubine to the Emperor but she could not find happiness as in the later part of her life, she lived alone without anybody to care for her.


5.0 Pope Joan


Pope Joan was a woman who lived her life as a man and went on to become the Pope in the th century. When she was twelve, Joan dressed as a boy, not only to protect herself but it was also the only way she could learn theology. During her time, women were not allowed to study, "Women weren't allowed in the library" (8). We can see how determined Joan was that she was willing to pretend to be a boy even at that young age. Her determination and courage is something to be looked up at but she had to dress up as a boy to do this. Joan had to hide behind a boy's appearance to be someone.


Later on, when Joan was made a Cardinal, she felt ill and for two weeks she did not speak to any one as she was full of terror and regret. Perhaps she was afraid that her disguise might be found out or it could be that she was guilty of her success as she got it through pretending to be a man. It could also be the fact that to be given such heavy responsibility had made her anxious. It can be clearly seen that Joan went through a lot of unhappiness and guilt in her pursue of a career. Later, she was made a Pope, the highest post in the Christian religion. One can see that Joan has become a very successful person as she was at the pinnacle of her career. During the conversation among the group of women, one could sense the power that Pope Joan held over the people when she stated quite briefly, "I never obeyed anyone. They all obeyed me"(1). We must not forget that this is a woman who lived in the th century and she made men to obey her and kiss her feet. This is definitely a feat hard to follow.


On the other hand, it is clear that Joan did not find much happiness in her life. All her live, she lived in pretence. She has to sacrifice her feminine side in order to pursue a career. Furthermore, Pope Joan is ridden with guilt as she held the notion that God does not speak to women. She thought that once she was made the Pope, she would be able to communicate with God and know everything. This proved to be false and she thought it was because she was a woman, "I thought God would speak to me directly, but of course he knew I was a woman" (14). God is seen here as someone who is bias as God only communicates with men and not women.


Pope Joan could have led a successful life until the end if it was not for her lust. She became pregnant and had no means of getting rid of the baby as she did not know how. She gave birth to a child in the middle of the street during a procession. As the result of the embarrassment and humiliation she caused the church, Joan was stoned to death together with her child. It was a tragic end to someone as intelligent as her. In her conversation among the group of women, Joan sates,


I shouldn't have been a woman. Women, children and lunatics


can't be Pope. (15)


There is a lot of frustration in Joan. Joan knew that she would have been a very good Pope if she had carried on but the fact was, she was born a woman, and as a woman, there was nothing she could do or accomplish in a male-dominated society.


Similar to all the other women characters such as Marlene, Isabella and Nijo, Pope Joan achieved great success in her career but there was a lot of unhappiness in her life. She had to live her life pretending to be a male. She had no freedom to be herself. Although she enjoyed the life of comfort and luxury of being the Pope, guilt was eating her up as she knew that God knew the truth. Pope Joan had to sacrifice her happiness and freedom to be successful in the male dominated world.


6.0 Griselda


Griselda is a woman who lived around the 1th century. She is portrayed as an obedient wife who is too good to be true. Churchill introduces Griselda by stating that she "arrives unnoticed' to the party hosted by Marlene. Perhaps Churchill wants to show that just as how she was not noticed immediately by the group, Griselda's sacrifice and success in her life also went unnoticed and unappreciated by her husband.


Griselda's wedding was like a fairy tale, where the poor peasant girl was rescued by a rich marquis. What started off as a fairy tale, did not continue to be one. Griselda, as the obedient and dutiful wife, did not once question any of her husband's actions. Griselda knew her wifely duties very well.


But of course a wife must obey her husband./And of course


I must obey the Marquis. (1)


Even when Marlene was critical of her husband, Walter, Griselda was quick to defend him, saying that Walter really loved her.


He was very kind/ I'm sure he loved me, Marlene,


all the time. ()


Perhaps Griselda was just trying to convince herself that her husband's love for her was genuine and deep. The phrase, "I'm sure he loved me" suggest an uncertainty in Griselda's part. She was not firm in making the statement. Thus this could suggest that Griselda herself has doubts of her husband's love towards her.


What brings out Griselda as a strong character is that she had endured all her suffering with a lot of courage. Griselda had to give up her first-born, a daughter, to prove her loyalty towards her husband. She was willing to be separated from her child and knowing that her child would be killed, she still gave her daughter without any struggle as she had promised her husband that she would obey him. When her husband asked for their daughter with the intent of murdering the baby, Griselda gave her up willingly to show her obedience to her husband.


I asked him to give her back so I could kiss her. And


I asked him to bury her where no animals could dig


her up./It was Walter's child to do what he liked with.()


Griselda felt that her husband had all the right to do what he wanted with their child. She did not harbour any ill feelings towards her husband and stated that "We were very happy together. We never spoke about what had happened" (). Perhaps it was the fact that they never spoke about it, helped their relationship because her husband did not have to defend his actions to her. Six years later, Griselda again was willing to give up her two-year-old son because her husband had asked her to. All he had to do was ask, and she was willing to obey. What freedom or happiness does she get for being such an obedient wife? All she ever endures is the suffering of giving up her children. When Nijo asked her if it was easier or harder to give up her child the second time, Griselda simply replied,


It was always easy because I always knew I would


do what he said"()


It is always not easy to give up a child, especially if you have nurtured the child for two years. What her husband asked her to do was a sacrifice that no mother would want to face. However Griselda had promised to obey her husband and this is the principal she holds on to. No matter what happens, her husband's happiness always comes first. Griselda's success is seen through her obedience to her husband. She has no freedom to choose what she wants. Everything is dictated by her husband.


Twelve years after taking away her son, her husband wanted to be separated from her. The explanation he gave for sending her away was that the people wanted him to remarry so that he could produce an heir. What is ironic here is that he was given an heir when Griselda gave birth to a son but he took it away. Now he claims that he needs to remarry so that he would have an heir. Griselda never objected to being sent away. In fact, she volunteered to go back to her father because she knew that was what he wanted.


So I said I'd go home to my father. I came with nothing/


so I went with nothing. I took of my clothes. He let me


keep a slip so he wouldn't be shamed/ I was perfectly


content. (4)


Griselda gladly accepted her fate. She did not make a scene or accuse her husband of anything. She did not demand for anything and left to her father's house with no clothes except for a slip. I believe she would have gladly even left without a slip if it would not embarrass her husband. That was the extent of her obedience. On the other hand, perhaps, Griselda is void of any feelings because she had accepted and endured a lot of hardship and struggle in her life. Thus being sent away is not something new to her. This could explain why she did not show any emotion and accepted her fate without question.


Griselda did not have much happiness in her life as her children were taken away from her and later she was left by her husband. However, towards the end, Griselda did have some happiness when she was called back to her husband's house and was presented with her children. Griselda was over-joyed because her husband did not kill the children as she had thought. Perhaps, for all the struggle and hardship she has gone through, she was finally rewarded. Even until the end, Griselda, the ever dutiful wife, did not blame her husband for all the hardship she went through. In fact, she stated that her husband also "suffered so much all these years" (5). No one can go through life as Griselda did. She showed a lot of admirable qualities in enduring her life and came out of it with success and was rewarded in the end with happiness.


7.0. Louise


Louise is a 46 years old lady who had worked for the same company for the past 0 years. She came to the employment agency to look for a better job than her present one. Win, who was interviewing Louise, commented on her age. For a woman, being old can be seen as a disadvantage in finding for a job.


Louise Forty-six


Win It's not necessarily a handicap, well it is of course


we have to face that, but it's not necessarily a


disabling handicap, experience does count for something. (51)


Being middle-aged for a woman can be seen as a barrier to attain good jobs. During the interview, win suggested Louise applies for jobs that are catered more for women. There are two reasons for Win's suggestion. First, Louise would have to compete with younger men and second, being above 40 and a woman, chances for Louise to get a job is very slim.


vacancies are going to be ones where you'll be in competition


with younger men… There are also fields that are easier for a


women, there is a cosmetic company here where your experience


might be relevant. (5-5)


In a business-world dominated by men, experience does not count much if one is a female.


The reason Louise is unhappy with her present job, is the fact that she had been overlooked when it comes to promotion. She had been doing the same job for 0 years. Men, far younger than her, have all been promoted to better jobs.


I've seen young men who I trained go on, in my own


company or elsewhere, to higher things. Nobody notices


me, I don't expect it, I don't attract attention by making


mistakes, everybody takes it for granted that my work


is perfect. (5)


Although Louise is a good worker who hardly makes any mistakes, she felt that she was overlooked for any promotion because she was a female.


Louise herself acts like a man. Being a woman, she looks down on other women's capabilities of doing a job. This is evidently clear when she stated,


There was one, she was my assistant, it was the only time


I took on a young woman assistant. I always had my doubts.


I don't care greatly for working with women. (5)


Louise does not trust another woman to do a job well. There was only once she had a woman to assist her. Instead of helping other female to come up in a male dominated-business world, Louise expresses her doubts on another female carrying her duties well. Not only does Louise have a male attitude, she also compares herself to a man. "I think I pass as a man at work". (5) Perhaps she is comparing herself to a man to show the extent of how hard she works. She sacrificed her social life for the company that she works for.


I've lived for that company, I've given my life really you


Could say because I haven't had a great deal of social life.


I've worked in the evenings. (51-5)


Louise felt that even though she worked hard and dedicated her life for the company, she was not appreciated. Louise is extremely unhappy trying to compete with men.


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