Foundations of Critical Care Essay Example | Topics and Well Written Essays - 3000 words

Foundations of Critical Care - Essay Example Since this involved events surrounding a complex decision making at higher level where I am being guided by my mentor consistently, I felt John's model of structured reflection will be useful, and I will follow that in this reflective process (Johns, 1995, 226-235). Consequently, I will pay greater attention to my thoughts and emotions surrounding this event of my recent past experiences. This is the story of a patient whom I cared for in my placement in the critical care unit. In my placement in the critical care unit, my mentor assigned this patient to me. This is a middle-aged female patient who had abdominal surgery for her Crohn's disease and had been transferred to the intensive care unit for stabilization in a critical condition following anaesthesia. The intention of admission was to stabilize her and help her complete recovery form anesthesia so she can be extubated in the intensive care unit (Adam and Osbourne, 2005, 1-11). At assignment, I assessed her to find that she was sedated, was having very poor spontaneous breathing response, and intubated. She was connected to monitors, and a central venous pressure (CVP) line was inserted. A separate IV line was there, and it was running frusemide infusion at 2 mg/h since she was quite edematous. She was also advised hydrocortisone 50 mg intravenously three times a day along with her medications (Evans, 1998, 8-1 2). They diagnosed her to be in acute renal failure, and the management was expectant in that it would lead resolution of renal failure quickly. On my systematic assessment on assignment, my examination revealed that she has moderate oozing from her abdominal wound. However, her urine output was less than 40 mL/h, and from the urine in the bag, I thought that her urine was very concentrated. This is unlikely in an edematous patient with frusemide infusion. She was connected to ventilator at a PEEP of 10 to support her breathing. The striking feature was that her CVP was falling (Fitzpatrick and Donnelly, 1997, 271-279), and at the time of my care it was at 6. This was an obvious incongruence, and I discussed this with the Junior Doctor about her situation and requested him to reassess the condition. The doctor refused to relook at the situation and told that it was going fine. I felt frustrated since this patient needed to be assessed immediately for revising the management plan, an d I had hardly anything to do (Dowling et al., 1996, 1211-1214). Significant Issues From my academic learning, I knew that acute renal failure is not uncommon in a patient with prolonged and mutilative surgery. However, the care management must be collaborative in the critical care setting, since nurses remain closely attached to the patients during care delivery monitoring the patient on a minute-to-minute basis. Therefore, I felt I have a chance to know her progress or deterioration better than anyone else (Hudak & Galo, 1997, 16-26). Quite frequently, acute renal failures in postoperative patients are results of fluid depletion or dehydration, since the volume loss in the intraoperative period can be inadequately noticed. As the nurse in charge of her care, I felt the urge to actively participate in her care, and my input from that angle was to reassess her fluid status once again and to

American Political System and Philosophy Essay Example for Free

American Political System and Philosophy Essay The United States of America would have been completely different had the Founding Fathers been influenced by a different philosophical stream. Had democracy not been the cornerstone of the nation, Americans would not be enjoying the rights they have today. Democracy, in its literal meaning, suggests that the power of the state rests on its constituents and that, therefore, the fate of the country solely depends on its people. Without a democratic system, there will be no elections and no representations in the political arena. Since elections provide the means for the people to constantly shape the course of the nation’s institutions through elected officials, the lack thereof deprives Americans of their right to steer their country towards the direction which they see best fits their needs. For the most part, the Founding Founders perfectly embodied the noble principle of democracy in three simple words—â€Å"We the People†. If the political philosophy of Thomas Hobbes became the foundation of America, Americans will be forced to surrender their rights to a single authority. In effect, Americans will be left powerless as the â€Å"Leviathan† would have now held and wielded the aggregate of all their rights. The limitation of the political philosophy of Hobbes is clear—it does not recognize a large number of the rights of the people, more so their inalienable rights. Without recognizing the rights of the people, society becomes either lifeless or mechanical as individuals are forced to follow whatever the sitting authority dictates. In the society of Hobbes, Americans have no right to tell the ruler what to do. In some cases, modern Americans are unable to convince their local officials to do as they are told by their constituents. Rather, some local officials play deaf and mute to the calls of their constituents to make certain actions that will favor the larger body politic instead of a few chosen elites. If the political philosophy of John Stuart Mill became the foundation of America, the political system would have been chosen depending on the greatest good for the greatest number. In short, the political system will essentially be a Utilitarian system. In such a system, certain harms towards some Americans are permissible so long as the majority of the population is able to gain the best benefit. It then becomes clear that human rights violations are permissible if such violations would realize the best interest of the people. For example, the murder of thieves vigilante groups commit becomes acceptable because it reduces the possible sources of threats to life and property to most Americans. In the long run, the rule of law becomes parallel to the rule of the majority. Minorities who stand in opposition to the principles and ideals of the majority become powerless and are reduced to â€Å"toothless† citizens of the nation unable to change the social situation. Oftentimes, modern American culture reflects the Utilitarian perspective. One compelling example is the time when African-Americans were racially discriminated. Their discrimination was left unattended to by the federal government at that time primarily because most of the American population such as the â€Å"conservatives† benefitted from the oppression—benefit as in the context of their perception. I think the political philosophy of John Locke best reflects the formation of America as a nation. Locke primarily espouses the idea that men in the State of Nature would come together and transfer the power to punish transgressors to the government. Although the will of the majority requires all people to follow that will, the government plays the role of judge in times when offenses towards the people occur. The society formed from convention of people comes with certain laws that guide the actions of all people and serve as an adjudicating force with the aid of judges. Today, much of Locke’s political philosophy can be observed in America. The country has its own set of laws that guide the conducts of its citizens. Although the will of the majority is observed especially during elections, it does not necessarily deprive the minority of their rights and privileges in the society. As a matter of fact, American laws, in principle, do not discriminate between those who belong to the majority and those who are from the minority. All people are equal before the law.

The Role of Television in Ending Segregaation in the United States Essa

The Role of Television in Ending Segregaation in the United States In 1964 segregation was banned in public places as part of The Civil Rights Act. Leading on from this, things for black Americans improved until in the 1987 17 large US cities even had black mayors. But before these times there was segregation everywhere, from schools and restaurants to buses and water fountains. Black and white Americans simply did not mix. The decision for desegregation leads from a number of things, with various forms of media playing a central part, including television, and without this, could desegregation really have been obtained at all? By the time of desegregation in the USA, almost everybody had a television and watched it frequently. News programmes were on frequently and viewed by many. These highlighted the problems of racial tension, mainly by the reports ran on real events such as protests and marches and therefore showed the truth, with eye-witnesses being interviewed and photographs being broadcasting. An example of these photographs is in Source G, an image of Birmingham, Alabama in 1963, showing civil rights protesters. It shows great racial tension and the abuse faced by Negroes, which moved white citizens, gaining sympathy and support for the black Americans and the cause that they were fighting for. Although there were these sorts of images in newspapers, the television had more affect, with the pictures being right in front of you and viewers could see that it as real. For the first time it was recognised properly that racial discrimination was a national problem that needed to be resolved, and as it says in Source H, an... ... with the police. Despite this it got them a lot of publicity, bringing the problem frequently in the public eye and causing people to take notice of what was going on. It was publicity and keeping the issue on the surface that caused the changes to be made, but without the forms of media such as newspapers and television, the country would not have known about the extremity of the racism so the groups would have had no success in anything but provoking their local area. Although, as the author of Source I believes, television played a crucial part in ending segregation in the USA, without the other forms of media discussed backing it up, television would have not made any difference to the situation of racism. It takes the contribution of all media types for any one of them to have any kind of impact of segregation.

The Stupidest Angel Chapter 7

Chapter 7 MORNING IS BROKEN It was Wednesday morning, three days before Christmas, when Lena Marquez awoke to find a strange man in her bed. The phone was ringing and the guy next to her made a moaning sound. He was partially covered by the sheets, but Lena was pretty sure that he was naked. â€Å"Hello,† she said into the phone. She lifted the sheet to look. Yep, he was naked. â€Å"Lena, there's supposed to be a storm on Christmas Eve and we were going to have Mavis barbecue for Lonesome Christmas but she can't if it's raining and I yelled at Theo last night and went out and walked around in the dark for two hours and I think he thinks I'm crazy and you should probably know that Dale didn't come home last night and his new – uh, the other, uh – the woman he lives with called Theo in a panic and he – ; â€Å"Molly?† â€Å"Yeah, hi, how you doing?† Lena looked at the clock on the nightstand, then back at the naked man. â€Å"Molly, it's six-thirty.† â€Å"Thanks. It's sixty-seven degrees here. I can see the thermometer outside.† â€Å"What's wrong?† â€Å"I just told you: storm coming. Theo doubts sanity. Dale missing.† Tucker Case rolled over, and despite being half asleep, he appeared to be ready for action. â€Å"Well would you look at that,† Lena thought to herself, then she realized she'd said it into the phone. â€Å"What?† said Molly. Tuck opened his eyes and smiled at her, then followed her gaze south. He pulled the sheet out of her hand and covered himself. â€Å"That's not for you. I just have to pee.† â€Å"Sorry,† Lena said, pulling the sheet quickly over her head. It had been a long time since she'd had to worry about it, but she suddenly remembered a magazine article about not letting a man see you first thing in the morning unless he'd known you for at least three weeks. â€Å"Who was that?† Molly said. Lena made an eye tunnel in the sheet and looked out at Tucker Case, who was getting out of bed, totally unself-conscious, totally naked, his unit leading him into the bathroom, waving before him like a divining rod. She realized right then that she could always find new reasons to resent the male of the species – unself-consciousness was going on the list. â€Å"No one,† Lena said into the phone. â€Å"Lena, you did not sleep with your ex again? Tell me you are not in bed with Dale.† â€Å"I'm not in bed with Dale.† Then the whole night came rolling back on her and she thought she might throw up. Tucker Case had made her forget for a while. Okay, maybe she could count that as a positive toward men, but the anxiety was back. She'd killed Dale. She was going to jail. But she needed to pretend she didn't know anything. â€Å"What did you say about Dale, Molly?† â€Å"So who are you in bed with?† â€Å"Dammit, Molly, what happened to Dale?† She hoped she sounded convincing. â€Å"I don't know. His new girlfriend called and said he didn't come home after the Caribou Christmas party. I just thought you should know, you know, in case it turns out that something bad happened.† â€Å"I'm sure he's okay. He probably just met some tramp at the Head of the Slug and sold her on his workingman charm.† â€Å"Yuck,† Molly said. â€Å"Oh, sorry. Look, Lena, they said on the news this morning that a big storm is coming in off the Pacific. We're going to have El Ni;o this year. We have to figure out something for the food for Lonesome Christmas – not to mention what to do if a lot of people show up. The chapel is awfully small.† Lena was still trying to figure out what to do about Dale. She wanted to tell Molly. If anybody would understand, it would be Molly. Lena had been around a couple of times when Molly had gone through her â€Å"breaks.† She understood things getting out of control. â€Å"Look, Molly, I need – ; â€Å"And I yelled at Theo last night, Lena. Really bad. He hasn't taken off like that in a long time. I may have fucked Christmas up.† â€Å"Don't be silly, Mol, you couldn't do that. Theo understands.† Meaning, He knows you're crazy and loves you anyway. Just then, Tucker Case came back into the room, retrieved his pants from the floor, and started pulling them on. â€Å"I've got to go feed the bat,† Tuck said. He pulled a banana partially out of his front pocket. Lena threw the sheets off her head and tried to think of something to say. Tuck grinned, pulling the banana all the way out. â€Å"Oh, you thought I was just glad to see you?† â€Å"Uh – I – shit.† Tuck stepped over and kissed her eyebrow. â€Å"I am glad to see you,† he said. â€Å"But I have to feed the bat, too. I'll be right back.† He walked out of the room, barefoot and shirtless. Okay, he probably would be back. â€Å"Lena, who was that? Tell me?† Lena realized that she was still holding the phone. â€Å"Look, Molly, I'll have to call you back, okay? We'll figure something out for Friday night.† â€Å"But, I have to make amends –  » â€Å"I'll call you.† Lena hung up and crawled out of bed. If she was quick she could wash her face and get some mascara on before Tucker got back. She started zooming around the room, naked, until she felt someone watching her. There was a big bay window that looked out on a forest, and since her bedroom was on the second floor, it was like waking up in a tree house, but no one could possibly look in. She spun around and there, hanging from the gutter, was a giant fruit bat. And he was looking at her – no, not just looking at her, he was checking her out. She pulled the sheet off the bed and covered herself. â€Å"Go eat your banana,† she shouted at the bat. Roberto licked his chops. There had been a time, during his bong-rat years, when Theophilus Crowe would have stated, with little reservation, that he did not like surprises, that he preferred routine over variety, predictability over uncertainty, the known over the unknown. Then, a few years ago, while working on Pine Cove's last murder case, Theo had gotten to know and fallen in love with Molly Michon, the ex-scream queen of the B-movie silver screen, and everything changed. He had broken one of the cardinal rules – Never go to bed with anyone crazier than yourself – and he'd been loving life ever since. They had their little agreement, if he stayed off his drug (pot) she'd stay on hers (antipsychotics), and consequently she'd have his unmuddled attention and he'd only get the most pleasant aspects of the Warrior Babe persona that Molly sometimes slipped into. He'd learned to delight in her company and the occasional weirdness that she brought into his life. But last night had been too much for him. He'd come through the door wanting, nay, needing to share his bizarre story about the blond man, with the only person who actually might believe him and not berate him for being a stoner, and she had chosen that precise moment to lapse into hostile batshit mode. So, he'd fallen off the wagon, and by the time he returned to their cabin that night, he had smoked enough pot to put a Rastafarian choir in a coma. That's not what the pot patch he'd been growing had been for. Not at all. Not like the old days, when he maintained a small victory garden for personal use. No, the little forest of seven-foot sticky bud platforms that graced the edge of their lot on the ranch was purely a commercial endeavor, albeit for the right reason. For love. Over the years, even as the prospect of ever returning to the movies became more remote, Molly had continued to work out with her giant broadsword. Stripped to her underwear, or dressed in a sports bra and sweatpants, every day in the clearing in front of the cabin she'd declare â€Å"en garde† to an imaginary partner and proceed to spin, leap, thrust, parry, hack, and slash herself breathless. Beyond the fact that the ritual kept her incredibly fit, it made her happy, which, in turn, pleased Theo to no end. He'd even encouraged her to get involved in Japanese kendo, and to little surprise, she was excellent at it, consistently winning matches against opponents nearly twice her size. And indirectly, all this had led to Theo's growing pot commercially for the first time in his life. He'd tried other means, but banks seemed more than a little reluctant to lend him nearly a half year's salary in order to purchase a samurai sword. Well, not samurai precisely, but a Japanese sword – an ancient Japanese sword, made by the master swordmaker Hisakuni of Yamashiro in the late thirteenth century. Sixty thousand folded layers of high carbon steel, perfectly balanced, and razor sharp even eight hundred years later. It was a tashi, a curved cavalry sword, longer and heavier than the traditional katanas used later by samurais in ground combat. Molly would appreciate the weight during her workouts, as its heft was closer to that of the theatrical broadsword she'd brought with her as a legacy of her failed movie career. She would also appreciate that it was real, and Theo hoped that she'd see that it was his way of saying that he loved all the parts of her, even the War rior Babe (he just liked rubbing up against some parts more than others). The tashi was now wrapped in velvet and hiding at the back of the top shelf of Theo's closet, where he used to keep his bong collection. The money? Well, an old friend of Theo's from the stoner days, a Big Sur grower now turned wholesaler, had been happy to advance Theo the money against his crop. It was supposed to have been a purely commercial venture: get in, get out, and nobody gets hurt. But now Theo was showing up stoned for work for the first time in years, and following a bad night, he could just sense that this wasn't going to be a good day. Then the call came in from Dale Pearson's girlfriend/wife/whatever, and the descent into hell day started. Theo drowned his eyes in Visine and stopped at Brine's Bait, Tackle, and Fine Wines for a large coffee before he headed over to Lena Marquez's house in search of her ex-husband. While it was clear from the incident at the Thrifty-Mart on Monday, and a dozen earlier incidents, that their dislike for each other bordered on hatred, it hadn't stopped them from hooking up from time to time for some familiar post-divorce sex. Theo wouldn't have even known about it, except Molly was good friends with Lena and women talked about that sort of thing. Lena lived in a nice two-story Craftsman-style house on a half acre of pine forest that butted up to one of Pine Cove's many ranches. It was more house than she would have been able to afford working as a property manager, but then, she had put up with Dale Pearson for five years of marriage, and for five years since, so it was the least she deserved, Theo thought. He liked the sound of his hiking boots on the porch as he walked to the front door, and he thought that he and Molly should build a porch on their little cabin. He thought they could maybe get a wind chime, and a swing, have a little heater so they could sit outside on cold evenings. Then he realized, as he felt that vibration of footsteps coming to the door, that he was totally and completely baked. That they would know he was baked. That no amount of Visine or coffee was going to cover the fact that he was baked. Twenty years of functioning stoned was not going to serve him now – he'd lost his edge, he was no lo nger in the game, the eye of the tiger was bloodshot. â€Å"Hi, Theo,† Lena said, opening the door. She wore a man's oversize sweatshirt and red socks. Her long black hair, which normally flowed down her back like liquid satin, was all knotted up at the back of her head, and there was a big tangle sticking out by one ear. Sex hair. Theo shuffled on the porch like a kid getting ready to ask the girl next door for a first date. â€Å"I'm sorry to bother you so early, but I wondered if you've seen Dale. Since Monday, I mean.† She seemed to fade away from the door, like she was ready to faint. Theo was sure it was because she knew he was high. â€Å"No, Theo. Why?† â€Å"Well, uh, Betsy called, and said that Dale didn't come home last night.† Betsy was Dale's new wife/girlfriend/whatever. She was a waitress down at H.P.'s Cafe and over the years had become notorious for having affairs with a lot of married guys. â€Å"I was just, uh†¦Ã¢â‚¬  Why wouldn't she interrupt him? He didn't want to say that he knew that she and Dale got together for spite sex occasionally. He wasn't supposed to know.†Ã¢â‚¬ ¦ so, uh, I was just wondering.† â€Å"Hi, who's this?† said a blond guy who had appeared shirtless behind Lena in the doorway. â€Å"Oh, thank God,† Theo said, taking a deep breath. â€Å"I'm Theo Crowe, I'm the town constable.† He looked at Lena for an introduction. â€Å"This is Tucker – uh, Tuck.† She had no idea what this guy's last name was. â€Å"Tucker Case,† said Tucker Case, stepping around Lena and offering his hand to shake. â€Å"I should have introduced myself to you sooner, I guess, since we're in the same business.† â€Å"What business is that?† Theo never thought of himself as being a businessman, but he guessed that he was now. â€Å"I'm flying helicopter for the DEA,† said Tucker Case. â€Å"You know, infrared, finding growers and stuff.† Clear! His heart has stopped! Code blue! Five hundred milligrams of epinephrine, direct shot to the pericardium, stat! He's flatlining, people. Clear! â€Å"Nice to meet you,† Theo said, hoping his heart failure wasn't showing. â€Å"Well, sorry to bother you. I'll just be on my way.† He let go of Tuck's hand and started walking away, thinking: Don't walk stoned, don't walk stoned – for the love of God, how did I do this all of those years? â€Å"Uh, Constable,† Tuck said. â€Å"Why was it that you stopped by? Ouch!† Theo turned. Lena had just punched the pilot in the arm, evidently pretty hard – he was massaging it. â€Å"Uh, nothing. Just a fellow didn't go home last night, and I thought Lena might have an idea where he went.† Theo was trying to back away from the house, but then stopped, remembering that he might trip on the porch steps. How would he explain that to the DEA? â€Å"Last night? That's not even a missing person for, what, twenty-four, forty-eight hours? Ouch! Dammit, that's not necessary.† Tucker Case rubbed his shoulder where Lena had punched him again. Theo thought that she might have violence issues with men. Lena looked at Theo and grinned, as if she was embarrassed about the punch. â€Å"Theo, Molly called me this morning and told me about Dale. I told her I hadn't seen him. Didn't she tell you?† â€Å"Sure. Sure, she told me. I just, you know, I thought you might have some ideas. I mean, your friend is right, Dale's not really missing, officially, for another twelve hours or so, but, you know, it's a small town, and I, you know, have a job and stuff.† â€Å"Thanks, Theo,† Lena said, waving to him even though he was only a few feet away and wasn't moving away from the house. The pilot was waving, too, smiling. Theo didn't like being around new lovers who had just gotten laid, especially when things weren't going that well in his own love life. They seemed smug, even if they weren't trying to be. He spotted something dark swinging from the ceiling of the porch, right where the wind chime would have been on his and Molly's porch, if he hadn't just sacrificed their security by relapsing into dope-fiendism. It couldn't be what it looked like. â€Å"So, that's a, uh, that looks like –  » â€Å"A bat,† said Lena. Holy fuck, Theo thought, that thing is huge. â€Å"A bat,† he said. â€Å"Sure. Of course.† â€Å"Fruit bat,† Tucker Case clarified. â€Å"From Micronesia.† â€Å"Oh, right,† Theo said. Micronesia was not a real place. The blond guy was fucking with him. â€Å"Well, I'll see you guys.† â€Å"See you at Lonesome Christmas on Friday,† Lena said. â€Å"Say hi to Molly.† † ‘Kay,† Theo said, climbing into the Volvo. He closed the car door. They went inside. He let his head hit the steering wheel. They know, he thought. â€Å"He knows,† Lena said, her back against the front door. â€Å"He doesn't know.† â€Å"He's smarter than he looks. He knows.† â€Å"He doesn't know. And he didn't look dumb, he looked kind of stoned.† â€Å"No, he wasn't stoned, that was suspicion.† â€Å"Don't you think if he was suspicious he might have asked where you were last night?† â€Å"Well, he could see that, with you walking out there with your shirt off, and me looking so, you know – so – ; â€Å"Satisfied?† â€Å"No, I was going to say ‘disheveled. † She punched his arm. â€Å"Jeez, get over yourself.† â€Å"Ouch. That is completely out of line.† â€Å"I'm in trouble here,† Lena said. â€Å"You can at least be supportive.† â€Å"Supportive? I helped you hide the body. In some countries that implies commitment.† She wound up to punch him, then caught herself, but left her fist there in the air, just in case. â€Å"You really don't think he was suspicious?† â€Å"He didn't even ask why you have a giant fruit bat hanging out on your porch. He's oblivious. Just going through the motions.† â€Å"Why do I have a giant fruit bat hanging from the porch?† â€Å"Comes with the package.† He grinned and walked away. Now she felt stupid, standing there, her fist in the air. She felt unenlightened, dense, silly, unevolved, all the things she thought only other people were. She followed him into the bedroom, where he was putting on his shirt. â€Å"I'm sorry I hit you.† He rubbed his bruised shoulder. â€Å"You have tendencies. Should I hide your shovel?† â€Å"That's a horrible thing to say.† She almost punched him, but instead, trying to be more evolved, and less threatening, she put her arms around him. â€Å"It was an accident.† â€Å"Release me. I have to go spot bad guys with my helicopter,† he said, patting her on the bottom. â€Å"You're taking the bat with you, right?† â€Å"You don't want to hang out with him?† â€Å"No offense, but he's a little creepy.† â€Å"You have no idea,† said Tuck.

Zz Packer

ZZ Packer The Alternative Master Narrative â€Å"By our second day at Camp Crescendo, the girls in my Brownie troop had decided to kick the asses of each and every girl in Brownie Troop 909† (Packer p. 1). Not exactly how one would think a brownie girl would act, but that’s the trope, author ZZ Packer sets in every one of her stories, in Drinking Coffee Elsewhere. Like most authors, ZZ Packer has her own style of writing. She uses similar patterns and techniques throughout her collection of short stories.I will look at two of her stories and how they relate to her style of writing. â€Å"Brownies† is a story that many people of cultural value can relate too. This short story has many moral values in it. Brownies takes place at Camp Crescendo, a summer camp for fourth graders near the suburbs of Atlanta, Georgia. The story is told in first person by an African American girl named Laurel, also known as Snot. On the second day of camp Laurel announces to all the gir ls in her Brownie Troop that they were going to â€Å"kick the asses† of every girl in the troop, who were all white girls.The black girls disliked the white girls the minute they saw them. There ringleader Arnetta, said they smell â€Å"like chihuahuas. Wet chihuahuas† (Packer p2). The black girls have seen whites before, but they’ve never really had much to do with them. Being at the camp with them was the closest encounter they’ve ever had. which made it realistic and hard to not have any hatred towards them. This story is one of Packers most obvious labels that she usually talks about.As the story goes on, it follows another patten how the narrator of the story Laurel is a loner. Ever since the first grade she has always gotten made fun of, and got the nickname â€Å"Snot†. â€Å"The Ant of the Self† is another story that Packer talks about. It follows the themes of blacks to minorities, the presence of blacks on the east coast, and the main character Spurgeon is a â€Å"loner†. The Ant of the Self is a story about Spurgeon, the intelligent son of Ray Bivens Jr.Throughout the story he finds himself carrying the burden of supporting his self centered father on his shoulders. Ray doesn’t know the true meaning of an intimate relationship and is oblivious to his own son’s needs. When thinking about a father son relationship, you would imagine love, respect, laughter, and support, but when it comes to Spurgeon and his father, their relationship can be described as a business transaction. Spurgeon always supports his father, whatever it may be and he never gets any acknowledgement from his father for being there.In the beginning of the short story Spurgeon bails his father out of jail with money that he earned, and instead of his father showing appreciation or thanking him, he tells him â€Å"Opportunities. You’ve got to invest your money if you want opportunities† (Packer p82). The car ride home his Spurgeon’s father thinks of ways of making fast money, and comes up with an idea. Spurgeon tries telling his father that it’s a bad idea, but of course he doesn’t listen. This story, like many others ends with a the lack of a â€Å"happy ending†.

The Pied in The Pied Piper

The Pied in The Pied Piper The Pied in The Pied Piper The Pied in The Pied Piper By Maeve Maddox The Pied Piper is a character in a German folk tale popularized in English by Robert Browning in his poem â€Å"The Pied Piper of Hamelin.† In Browning’s version, a town corporation hires the Piper to rid their town of a plague of rats. They agree to pay what the Piper asks. When the rats are dead, however, the town leaders renege on the contract because the rats cannot be brought back. In retaliation, the Piper lures away their children, never to be seen again. The moral of the tale is that cheating people can have unexpected and dreadful consequences. The term â€Å"pied piper† has entered the language in the sense of someone who, by means of personal charm, entices people to follow him or her, usually to disappointment or misfortune. Browning’s Piper wears a long coat â€Å"from heel to head† which is â€Å"half of yellow and half of red.† The coat is what gives him his name. The adjective pied means â€Å"of two colors.† Originally, the two colors were black and white, the colors of a magpie. Magpie is where the â€Å"pie† comes from. The word usually refers to an animal with markings of two colors, especially a bird: pied kingfisher, pied flycatcher, pied finch, etc. In the Middle Ages, the Carmelites were called â€Å"pied friars† because their religious habit consisted of a brown tunic and a white cloak. The Benedictines and Cistercian monks were called â€Å"pied monks† because they wore a white tunic and a short black cloak. A pied horsepiebald has black and white patches, although some speakers use the word pied or piebald to describe patches of any differing colors. Another type of pied horse is called a skewbald: When the white is mixed with black it is called pie-bald, with bay the name of skew-bald is given to it. –Youatts The Horse, 1866. The term pied piper is popular with writers on the Web, although what they mean by it is often difficult to discern: Rufus Harley: the Pied Piper of jazz Todd is the Pied Piper of cool Steve Gryb: the Pied Piper of Percussion Mohamed El Baradei: Globalist Pied Piper of the Egyptian Revolt Seligman: the Pied Piper of positive psychology Ryan McGinley, the Pied Piper of the Downtown Art World Jerry Kapstein: the Pied Piper of Free Agents Headlines are innately ambiguous, but here’s a reference that definitely departs from the traditional meaning of pied piper as â€Å"someone charming who leads his followers to misfortune†: Hes a team guy and just beloved by people that know him. Hes very pleasant to be around. Hes like the Pied Piper, Lamb said. Perhaps a revival of Browning’s poem is in order. In our age of skullduggery, the topic remains timely. Besides, it’s fun to read aloud. Here are a few lines to get you started: Rats!   They fought the dogs and killed the cats,   And bit the babies in the cradles,   And ate the cheeses out of the vats,   And licked the soup from the cooks own ladles,   Split open the kegs of salted sprats,   Made nests inside mens Sunday hats,   And even spoiled the womens chats,   By drowning their speaking   With shrieking and squeaking   In fifty different sharps and flats. You can read it all here: †The Pied Piper of Hamelin† by Robert Browning. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Vocabulary category, check our popular posts, or choose a related post below:Math or Maths?41 Words That Are Better Than GoodKn- Words in English

10 Tips for Getting Along With Your College Roommate

10 Tips for Getting Along With Your College Roommate You may have grown up living with lots of siblings, or this may be your first time sharing your living space with someone else. While having a roommate inevitably has its challenges, it can also be a great part of your college experience. Follow these ten tips to make sure you and your roommate keep things pleasant and supportive throughout the year (or even years!). 1. Be Clear About Your Expectations From the Beginning Do you know in advance that you hate it when someone hits the snooze button fifteen times every morning? That youre a neat freak? That you need ten minutes to yourself before talking to anyone after you wake up? Let your roommate know as soon as you can about your little quirks and preferences. Its not fair to expect him or her to pick up on them right away, and communicating what you need is one of the best ways to eliminate problems before they become problems. 2. Address Problems When They're Little Is your roommate always forgetting her stuff for the shower, and taking yours? Are your clothes being borrowed faster than you can wash them? Addressing things that bug you while theyre still little can help your roommate be aware of something she may not otherwise know. And addressing little things is much easier than addressing them after theyve become big. 3. Respect Your Roommate's Stuff This may seem simple, but its probably one of the biggest reasons why roommates experience conflict. Dont think hell mind if you borrow his cleats for a quick soccer game? For all you know, you just stepped over an uncrossable line. Dont borrow, use, or take anything without getting permission first. 4. Be Mindful of Who You Bring Into Your Room- and How Often You may love having your study group into your room. But your roommate may not. Be mindful of how often you bring people over. If your roommate studies best in the quiet, and you study best in a group, can you alternate who hits the library and who gets the room? 5. Lock the Door and Windows This may seem like it has nothing to do with  roommate relationships, but how would you feel if your roommates laptop got stolen during the ten seconds it took you to run down the hall? Or vice versa? Locking your door and windows is a critical part of keeping safe on campus. 6. Be Friendly, Without Expecting to Be Best Friends Dont go into your roommate relationship thinking that you are going to be best friends for the time youre at school. It may happen, but expecting it sets both of you up for trouble. You should be friendly with your roommate but also make sure you have your own social circles. 7. Be Open to New Things Your roommate may be from someplace youve never heard of. They may have a religion or lifestyle that is completely different from your own. Be open to new ideas and experiences, especially as it to relates to what your roommate brings into your life. Thats why you went to college in the first place, right?! 8. Stay Open to Change You should expect to learn and grown and change during your time at school. And the same should happen to your roommate, if all goes well. As the semester progresses, realize things will change for both of you. Be comfortable addressing things that unexpectedly come up, setting new rules, and being flexible to your changing environment 9. Address Problems When They're Big, Too You may not have been totally honest with tip #2, or you may suddenly find yourself with a roommate who goes wild after being shy and quiet the first two months. Either way, if something gets to be a big problem quickly, deal with it as soon as you can. 10. If Nothing Else, Follow the Golden Rule Treat your roommate like youd like to be treated. No matter what your relationship is at the end of the year, you can take comfort knowing you acted like an adult and treated your roommate with respect. Dont think you and your roommate are going to be able to work it out? It can be easier than you think to address your problems and, ideally, find a solution that works for both of you.

Profile of Demeter the Greek Goddess

Profile of Demeter the Greek Goddess Demeter is a goddess of fertility, grain, and agriculture. She is pictured as a mature motherly figure. Although she is the goddess who taught mankind about agriculture, she is also the goddess responsible for creating winter and a mystery religious cult. She is usually accompanied by her daughter Persephone. Occupation: Goddess The family of Origin: Demeter was a daughter of the Titans Cronus and Rhea, and so a sister of the goddesses Hestia and Hera, and the gods Poseidon, Hades, and Zeus. Demeter in Rome: The Romans referred to Demeter as Ceres. The Roman cult of Ceres was initially served by Greek priestesses, according to Cicero in his Pro Balbo oration. For the passage, see Turas Ceres. In Graeco Ritu: A Typically Roman Way of Honoring the Gods [Harvard Studies in Classical Philology, Vol. 97, Greece in Rome: Influence, Integration, Resistance (1995), pp. 15-31], author John Scheid says the foreign, Greek cult of Ceres was imported to Rome in the middle of the third century B.C. Ceres was also referred to as Dea Dia in connection with a three-day May Ambarvalia festival, according to Tibullus and the Ambarvalia, by C. Bennett Pascal, in The American Journal of Philology, Vol. 109, No. 4 (Winter, 1988), pp. 523-536. Also see Ovids Amores Book III.X, in an English translation: No Sex Its the Festival Of Ceres. Attributes: The attributes of Demeter are a sheaf of grain, a conical headdress, a scepter, a torch, and a sacrificial bowl. Persephone and Demeter: The story of Demeter is usually combined with the story of the abduction of her daughter Persephone. Read this story in the Homeric Hymn to Demeter. Eleusinian Mystery: Demeter and her daughter are at the center of the widest spread Greek mystery cult the Eleusinian Mysteries a mystery religion that was popular in Greece and in the Roman Empire. Named for the location in Eleusis, the mystery cult may have started in the Mycenaean period, according to Helene P. Foley, in The Homeric hymn to Demeter: translation, commentary, and interpretive essays. She says that substantial remains of the cult begin in the 8th century B.C., and that the Goths destroyed the sanctuary a few years before the start of the fifth century A.D. The Homeric Hymn to Demeter is the oldest record of the Eleusinian Mysteries, but it is a mystery and we dont really know what transpired. Mystery Cults of the Ancient World Review Myths Involving Demeter: Myths about Demeter (Ceres) re-told by Thomas Bulfinch include: ProserpineThe Rural DeitiesCupid and Psyche Orphic Hymn to Demeter (Ceres): Above, I provided a link to the so-called Homeric Hymn to Demeter (in public domain English translation). It tells of the abduction of Demeters daughter Persephone and the trials the mother went through to find her again. The Orphic hymn paints a picture of the nurturing, fertility goddess. XXXIX.TO CERES. O Universal mother, Ceres famdAugust, the source of wealth, and various namd: 2Great nurse, all-bounteous, blessed and divine,Who joyst in peace, to nourish corn is thine:Goddess of seed, of fruits abundant, fair, 5Harvest and threshing, are thy constant care;Who dwellst in Eleusinas seats retird,Lovely, delightful queen, by all desird.Nurse of all mortals, whose benignant mind,First ploughing oxen to the yoke confind; 10And gave to men, what natures wants require,With plenteous means of bliss which all desire.In verdure flourishing in honor bright,Assessor of great Bacchus, bearing light: Rejoicing in the reapers sickles, kind, 15Whose nature lucid, earthly, pure, we find.Prolific, venerable, Nurse divine,Thy daughter loving, holy Proserpine:A car with dragons yokd, tis thine to guide, 19And orgies singing round thy throne to ride: 20Only-begotten, much-producing queen,All flowers are thine and fruits of lovely green.Bright Goddess, come, with Summers rich increaseSwelling and pregnant, leading smiling Peace;Come, with fair Concord and imperial Health, 25And join with these a needful store of wealth. From: The Hymns of OrpheusTranslated by Thomas Taylor [1792]

Not required Essay Example | Topics and Well Written Essays - 1500 words

Not required - Essay Example This cohesion between airline companies results to better perform in relation to customer service as well as the air transport. Although the extent of cohesion varies across alliances, it has been observed that they are more profitable to small airline entities. This essay will look at the three major airline airlines that are recognized on the international platform including Oneworld, Star Alliance and SkyTeam. Additionally, the essay looks into Alaska airline that is a key flyer in the US and other international destinations. Finally, the paper looks into the advantages and disadvantages of global airlines. This is the first airline global alliance that is discussed in the paper. First, it is the smallest alliance that currently has thirteen members; however, this number is expected to rise in the coming years. The alliance was established in 1999 by the airline companies that were competing with Sky Team (Weber and Sparks, 2004). Examples of these members include: Qatar Airways, Malaysia Airlines, American Airlines and British Airways. The alliance has 981 destinations and it operates in 151 countries. The yearly capacity is 475 passengers; it has a fleet of 3,283 aircrafts and 14,244 departures on a daily. The top five members elect airlines that have the highest number of flights include TAM, British Airways, Iberaia, US Airways and American Airlines (The Points Guy, 2014). It can be argued the alliance is undeniably the best in redeeming domestic and global cabin topnotch awards. Six carriers have well-established global first rate cabins including Cathay Pacific, British Airways, American, Cathay Pacific, Malysian Airline, Qantas and JAL. This is the second global alliance in the airline industry. Based on the recent statistics, the alliance has nineteen members. This alliance was formed in 2000. It operates in 178 nations across the globe and has 1024

Case Study Example | Topics and Well Written Essays - 500 words - 51

Case Study Example A great deal of transparency has been created which has motivated the doctors to work harder. Felipe whose duties include marketing and contracting with managed care companies has also done well in his job. As a talented negotiator, he understands contracts and is good with people. He would be good at leading and managing employees since he has his master’s degree. With his engaging personality and involvement in community outreach, he has been able to improve the reputation of the center in the surrounding neighborhood. He is considered to have high integrity, as there has never been any hint of scandal associated with his name. He works many hours of time and is willing to give the time necessary to get something done. Amanda has a lot of experience since she has worked for the company for the last 10 years. She started as an office receptionist and worked her way up to the job of business office manager. She has that professional style and dresses well. She is able to motivate those around her since she is highly motivated to do a good job. She is well liked by her employees because she offers good coaching skills and gives credit for accomplishments. She rarely takes credit for herself and is able to instill confidence in those around her. Ambulatory Care Center, which is a medium-sized facility, needs to change in order for it to remain viable. The center used to serve a predominance of senior citizens who are a reflective of the immediate surrounding community. This is because in the neighborhood, more families are moving in as well as many young adults. The ethnicity of the neighborhood is changing with more families that originate from Hispania or of African to origin. The financial base that used to support the Center changed from payments that come from payments that come predominantly from payments that come predominantly from Medicare to a financial base that came from a combination of group insurance and cash patients. The Center

NutritionTracking patients with nutritional risks, how does your Essay

NutritionTracking patients with nutritional risks, how does your facility do it - Essay Example In addition, lab work is conducted by examining their protein level, albumin and pre albumin levels. Their LDL and HDL is checked along with vitamin B12 and folic acid levels are checked. Caloric intake is examined by ensuring that patients are taking actual food. Fluid intake is also examined. One of the main aspects that hospitals focus their attention is on pregnant mothers. In order to understand and formulate risks associated with pregnancy, nurses have come up with criteria. If the mother demonstrates multiple gestation, that’s a bad sign. Additionally, gestational diabetes can be detrimental and must be recorded right away. Any dramatic change of 10 to 50 pound weight gain is not healthy. Furthermore, patient’s history of weight loss surgery should be obtained. Nurses and dieticians are majority in charge of handling patient’s nutritional status. Most patients that are sick tend to lose weight and must be supplemented with proper amount of food and nutrients. Conducive research indicates that as many as 65% of elderly patients are malnourished when they enter the hospital while in the hospital. Without having the proper nutritional assessment, it is highly illogical and difficult to monitor their status. Nutrition is integrated into the nursing plan through various ways. If the patient does not need a nutritional consult then the next step is to enroll them in a diet program. Their diet is ordered and is document regarding how much consumption is taken. If a nutritional consult is ordered the dietician makes sure the patient is getting enough nutrients and calories to support a healthy life function. Anthropometric refers to overall growth of human body. These measurements commonly are used to measure development in growth for infants. Growth is obtained and evaluated through length, weight and head circumference. A growth chart lists all the standards of benchmark through previous average

Education and training Essay Example | Topics and Well Written Essays - 250 words

Education and training - Essay Example In this age that Smart calls the Symbiotic Age, machines will be called upon to interpret human language and intent. And it is in this regard that the conversational interface technology will become irreplaceable. So what exactly are CUIs? A simple definition would be to refer to CUIs as technologies that shall enable us to use our natural communication modes such as gestures and speech to communicate with computers and other digital systems. This would naturally eliminate the need for users to frequently undergo special training as newer technologies emerge because the future gadgets will be tuned to comprehend our voice, gestures and even intent. CUIs are currently categorized into three. The most common CUIs that we use on a daily basis are the directed dialogue CUIs such as the automated customer care machines that are typical of mobile phone providers. Here our options are restricted through guided dialogue. We also have free-form CUIs and mixed initiative or mixed dialogue systems. free-form CUIs are where humans have full control and mixed dialogue systems resemble face-to-face conversations, where both machines and humans are equally empowered (Glass et. al., 2005). With increasing emphasis on online and e-learning we find that conversational interface technology would facilitate personalization of learning communication which is essential for student-based learning. A renowned scientist and expert in human cognitive development, Vygotsky’s stated that more learning takes place outside the classroom and in an era of increased social networking, we are of the opinion that CUIs could be used to promote collaborative learning through such social sites. However, a survey conducted by Rossett and Marshall in mid 2009 in the US inform us that we are still have a long way to go. Use of online discussions, Web 2.0 tools and e-learning to

The Business Plan Essay Example | Topics and Well Written Essays - 8250 words

The Business Plan - Essay Example Dark Horse Imports Inc. is dedicated to providing the Australian public with the best tasting, premium beer the world has to offer and also aims to control and distribute all SHAG related products for Australia. Dark Horse Inc. is a local management company in Australia which depends directly on The Spirit, Hop and Grape Company (Asia) Ltd. Dark Horse will import Shag lager from Malaysia and will take responsibilities of all the logistic process, from Malaysia to the final consumer, and also all the marketing and promotion activities. The management team for Shag is highly motivated and well qualified for the job. It will consist of Joseph P. Keenan II (CEO), Jacint Fit (CFO) and Benjamin Jeffery (Marketing and Sales). The first product that we will be launching will be SHAG, a premium lager "microbrew" type beer due to the lack of any real competition in this marketplace. The second product will be Blue SHAG Vodka plus, a delightful Vodka drink based with taurine, guarana and caffeine. The third product is a "fab" drink. Following the trend of "fab" drinks, SHAG will launch its own exciting range of fruit-flavoured fermented alcohol drinks. SHAG Beer: Brewed traditionally in Holland, with long lagering and fermentation process, Shag Lager has an alcoholic content of 5% ABV. Using natural spring water, superior malt, hops and yeast from Holland respectively. The end result is a premium lager superior to other major brands. Shag is supplied in 24-pack cases consisting of 300ML bottles in cluster (six-pack) packaging. Major Benefits - Superior Lager - Superior taste compared to other major brands in the market Potentially Strong Market Presence - for the growing and large Australian Beer Market Unique and Attractive Packaging Use of Superior Products from Holland Supplied in Convenient Packaging Blue SHAG Vodka plus: Vodka-based drink with taurine, guarana and caffeine. Described as being a better tasting product than most other Blue drinks, Blue Shag has an alcoholic content of 5.5% ABV. Its unique, 250ml bottle and their marketing plan through merchandising will ensure people keep coming back for more. Major Benefits- Unique Taste Aim for Customers 'wanting more' of Shag - 250 ml bottle Unique Marketing Plan Saleable as the Best Blue Drink in the market Appropriate Alcohol Content SHAG "fab": Following the trend if "fab" also called flavored alcoholic beverages, SHAG will launch its own exciting range of fruit-flavored, fermented alcohol drinks. Fab's has been widely credited with a maintained sales in an wider alcoholic drinks markets as the more traditional spirits markets decline . The combination of naturally fermented alcohol and delicious fruit juices will

History on the start of the U.S. Air Mail Term Paper

History on the start of the U.S. Air Mail - Term Paper Example Even the American Congress was not much interested in giving funding to the postal department for developing air mail system earlier. But the American military has come forward for the rescue of the postal department and they have extended great support to the postal department for developing air mail routes and to train the postal department pilots in using airplanes. Moreover, the American electrical companies has developed and provided navigation equipments for the usage of postal department planes and finally after watching the huge success of air mail system, American Congress also come forward to the rescue of the postal department. From there onwards American postal department never looked back and developed one of the most advanced air mail delivery system in the world. This paper analyses the American air mail history and early developments. Postal service was probably one of the ancient communication means in the world. Even though road, rail and sea paths were used earlier for mail deliveries, it caused lot of difficulties in sending and receiving mails through these mail methods. The need for fast delivery of mails has brought the idea of airmail delivery system. â€Å"THE FIRST aerial mail transportation may be traced back to 1870, when in that year letters were carried out of beleaguered Paris by free balloons, cast adrift in the winds.   The first of such flights was made on September 23, 1870, and carried 500 pounds of mail† (Keogh) The need for aerial route for fast mail delivery system has been realized even before the 20 th century. Most of the Airplanes which used earlier for war purposes were controlled by the military and hence air mail delivery using airplanes were not imaginable earlier. But the usefulness of airplanes in mail delivery has been realized by human kind at the beginning of the 20 th century itself and in countries like India, England and

The Business Plan Essay Example | Topics and Well Written Essays - 8250 words

The Business Plan - Essay Example Dark Horse Imports Inc. is dedicated to providing the Australian public with the best tasting, premium beer the world has to offer and also aims to control and distribute all SHAG related products for Australia. Dark Horse Inc. is a local management company in Australia which depends directly on The Spirit, Hop and Grape Company (Asia) Ltd. Dark Horse will import Shag lager from Malaysia and will take responsibilities of all the logistic process, from Malaysia to the final consumer, and also all the marketing and promotion activities. The management team for Shag is highly motivated and well qualified for the job. It will consist of Joseph P. Keenan II (CEO), Jacint Fit (CFO) and Benjamin Jeffery (Marketing and Sales). The first product that we will be launching will be SHAG, a premium lager "microbrew" type beer due to the lack of any real competition in this marketplace. The second product will be Blue SHAG Vodka plus, a delightful Vodka drink based with taurine, guarana and caffeine. The third product is a "fab" drink. Following the trend of "fab" drinks, SHAG will launch its own exciting range of fruit-flavoured fermented alcohol drinks. SHAG Beer: Brewed traditionally in Holland, with long lagering and fermentation process, Shag Lager has an alcoholic content of 5% ABV. Using natural spring water, superior malt, hops and yeast from Holland respectively. The end result is a premium lager superior to other major brands. Shag is supplied in 24-pack cases consisting of 300ML bottles in cluster (six-pack) packaging. Major Benefits - Superior Lager - Superior taste compared to other major brands in the market Potentially Strong Market Presence - for the growing and large Australian Beer Market Unique and Attractive Packaging Use of Superior Products from Holland Supplied in Convenient Packaging Blue SHAG Vodka plus: Vodka-based drink with taurine, guarana and caffeine. Described as being a better tasting product than most other Blue drinks, Blue Shag has an alcoholic content of 5.5% ABV. Its unique, 250ml bottle and their marketing plan through merchandising will ensure people keep coming back for more. Major Benefits- Unique Taste Aim for Customers 'wanting more' of Shag - 250 ml bottle Unique Marketing Plan Saleable as the Best Blue Drink in the market Appropriate Alcohol Content SHAG "fab": Following the trend if "fab" also called flavored alcoholic beverages, SHAG will launch its own exciting range of fruit-flavored, fermented alcohol drinks. Fab's has been widely credited with a maintained sales in an wider alcoholic drinks markets as the more traditional spirits markets decline . The combination of naturally fermented alcohol and delicious fruit juices will

Job Hunt Assignment Example | Topics and Well Written Essays - 500 words

Job Hunt - Assignment Example The accounting functions will include assessing the compliance of the financial statements with the relevant accounting standards. The main responsibilities of the professional being appointed as the internal financial auditor of the Financial Company will encompass auditing the financial reports of the company in accordance with the relevant accounting standards. The professional will also be liable to convey or report the standard and reliability of the financial statements produced by the company over a certain period of time. The Financial Company operates nationwide in the USA as one of the largest and most successful financial consultant firms, with its headquarter located in the City of Oak Brook, Illinois. The company can also be considered as one of the most respected and recognized brands across the nation with the intensive and constant efforts of more than 3000 employees. According to the present day context, it can be identified that the organization serves around 68 thousand business and individual customers through financial consulting in terms of tax planning, portfolio designing and business planning. With due regards for your kind considerations, I would like to thank you for providing a great opportunity to me with the offer of candidature in your interview session for the job vacancy of an internal financial auditor. I certainly appreciate for taking your time out of your busy schedule and talking to me concerning the post of Internal Financial Auditor in your organization. I would like to state in this regard that it was a pleasure to talk to you and obtain unambiguous learning of the expectations which the company has from me as a professional. After thinking about your offer and my job requirements, I believe that the respective position will provide me an incredible opportunity to apply my academic

High School Student And Adulthood Essay Example for Free

High School Student And Adulthood Essay â€Å"The power which resides in him is new in nature, and none but he knows what that is which he can do, nor does he know until he has tried.† Understanding Defines Change Psychologists Scott Scheer, Stephen Gavazzi, and David Blumenkrantz undertook a comprehensive review and analysis of the psychoanalytic literature that discussed the rites of passage in adolescence; from the reading, they derived two truths concerning an adolescent’s rite of passages. Primarily, as Scheer, Gavazzi, and Blumenkrantz state, â€Å"Not all transitional events necessarily indicate the occurrence of life transitions† (1); however, â€Å"It is believed that both cognitive interpretation and integration are required before the event genuinely becomes a significant transition or rite of passage† (1). Essentially, to label a singular event as one that ignited a life transition, one must understand the resulting effects of the event. Additionally, according to Scheer, Gavazzi, and Blumenkrantz, the event that marks the end of the transitional period between adolescence and adulthood defines the rite. Principally, a singular event cannot accelerate one’s progression into adulthood without one realizing the effects or changes that the event caused. In â€Å"Self-Reliance† by Ralph Waldo Emerson, Emerson described the idealistic depiction of the Romantic hero’s rite of passage. Emerson states that â€Å"The power which resides in him is new in nature† (1), and he believes that a person should seek the meaning of that power for himself. Emerson’s statement that one doesn’t know the power that they have until one finds it (1) falls directly in line with Scheer, Gavazzi, and Blumenkrantz’s interpretation of one’s rite of passage. Scheer, Gavazzi, and Blumenkrantz postulate that one cannot arrive at adulthood without first understanding a transitional event. Similarly, Emerson reveals, in the quote at the top of the page, that one does not know his unique power until he has tried to find it himself. Likewise, if one didn’t find their unique power, based on the definition given by Emerson, one hasn’t successfully arrived at that â€Å"Time in a man’s education† (1), and, thus, has not successfully completed a rite of passage. Therefore, Emerson views rites of passage as events that are intrinsically bound to understanding, and without cognitive interpretation, an event cannot allow one to find one’s unique power, disqualifying it as a rite of passage. The idea that rites of passages are dependent upon cognitive understanding holds true throughout a number of literary texts. For instance, in Walden by Henry David Thoreau, Thoreau details the rite of passage of a king’s son. As Thoreau states, â€Å"One of his father’s ministers having discovered him, revealed to him that he was, and the misconception of his character was removed, and he knew himself to be a prince† (72). Like Scheer, Gavazzi, and Blumenkrantz’s postulated, the son’s discovery alone did not result in the personality transition from that of a forester’s child to a prince. Instead, the son had to realize that he was, in fact, a prince before the transition could completely take effect. Thus, for one to totally embark and complete a rite of passage or a life transition, one must understand the effects of a singular event. (487) Works Cited Emerson, Ralph Waldo. â€Å"Self Reliance.† Adventures in American Literature: Pegasus Edition. Ed. Bernard Brodsky. Orlando: Harcourt, 2004. 221. Print. Scheer, Scott, et al. Rites of passage during adolescence. Forum. n. page. Web. 17 Feb. 2013. http://ncsu.edu/ffci/publications/2007/v12-n2-2007-summer-fall/scheer.php. Thoreau, Henry David. Walden. New York: Penguin Classics Publishing, 2005

US Dollar And Turkish Lira Exchange Rate

US Dollar And Turkish Lira Exchange Rate In finance, the exchange rates which are also known as the foreign-exchange rate, forex rate or FX rate between two currencies is how much one currency is worth in terms of the other. In other words, it is the value of a foreign countrys currency in terms of the home countrys currency. Furthermore, the foreign exchange market is considered as one of the largest markets dominating in the world, and approximately about 3.2 trillion USD of currency changes transactions takes place every day. Specific currencies become more valuable when demand for it is greater than its supply. On the other hand, it will become less valuable or in other words it will depreciate whenever demand becomes lower than its supply. Investors all over the world will probably choose to buy certain currencies only if the return on this particular currency is high. Therefore, the higher the countries interest rate, the greater will be the demand for that countries currency. We chose to compare the $U.S against the Turkish Lira as we know that turkey is a very strong country with a floating currency; that is, not fixed exchange rate. Turkey is well known and popular for exporting textiles and clothes all over the world and taking to consideration its past history at a stage in time it had ruled many parts of the world and so it was among the most powerful countries ruling most of the Arab countries. Therefore, we chose to select the Turkish Lira and compare it to exchange rates of the $U.S and analyze what events or factors have lead to the depreciation or the appreciation of the Turkish lira. Our aim in this research project is to develop a general understanding of the forex market world and be able to compare and analyze different markets in the exchange market as well as relating national and international events and factors contributing to the success or the failure of a particular currency. Moreover, we will gain the knowledge of tips of smart international business activities such as currency exchange investments for instance when to buy or sell certain goods under certain currencies. Turkey Economy Overview: Government Type: Parliamentary ,Representative, Democracy. Currency: Turkish Lira Turkey economic is largely dominated by modern industries and the services sector. Also, its one of the leading countries in world in producers of agricultural products; textiles; motor vehicles, ships and other transportation equipment; construction materials; consumer electronics and home appliances and they import non-auto consumer goods, fuels, production machinery and equipment, non-fuel industrial supplies, motor vehicles and parts, food, feed and beverages to partner in European Union, China, Canada, Mexico and Japan Furthermore, the gross domestic product it worth in December 2099 -6.50% -7.00% Jun 2009 of the world economy, according to the World Bank.  [1]   As we can see from the table above, the Turkish lira inflation rate has experienced a noticeable disinflation rates which is defined as the slowing in the rate of the inflation as well as a remarkable decline in the volatility of inflation which is due to some factors such as tight fiscal and monetary policies. However, previously since the 1970s and the 1990s the Turkish lira had been depreciating in its currency value due to turkeys constant inflation. US Economy Overview: Government Type: Constitution-based federal republic; strong democratic tradition. Currency: US Dollars. The economic history of the United States has the largest national economy in the world in both nominal and purchasing power parity. In addition, US have a stable overall GDP growth rate, a low unemployment rate, and high levels of research and capital investment. The United States Gross Domestic Product is worth in December 2009 -1.90% September 2009 -2.50% of the world economy, according to the World Bank. The US has several export import; first the export is machinery and equipment, industrial supplies, non-auto consumer goods, motor vehicles and parts, aircraft and parts, food, feed and beverage to partner Canada, European Union, Mexico, China and Japan. In addition, US import non-auto consumer goods, fuels, production machinery and equipment, non-fuel industrial supplies, motor vehicles and parts, food, feed and beverages. To the Main import partners are: European Union, China, Canada, and Mexico and Japan  [2]  . N/A ,0.03%(Jan 2009) Table Source: InflationData.com (2003- 2009). Inflation Rate in Percent for Jan 2000-Present. Retrieved on 8-12-2009. http://www.inflationdata.com/inflation/Inflation_Rate/CurrentInflation.asp On the other hand, U.S.A seems to have similar inflation rates across the years, as the U.S economy is considered to be the largest in the world. Forex rate system used in Turkey: Turkeys exchange rate has been changing over the past years and this can be related to its economy validated in many ways. In 1990-1997 Turkey exchange rate system was considered as a crawling band which means that the Currency is maintained within certain fluctuation margins around a central rate is adjusted periodically a fixed preannounce rate or in response to change in selective quantitative indicators  [3]  . However the exchange rate in 1998 -2000 was crawling peg which define as the currency is adjusted periodically in small amount at a fixed preannounce rate or in response to change in selective quantitative indicator.  [4]   Since 2001 the exchange rate change to independent floating which can be defined as the exchange rate is market determine with any foreign exchange intervention aimed to moderating the rate of change and preventing undue fluctuation in the exchange rate rather than at establishing a level for it  [5]  . This change has taken place after the financial crisis the country had at the same time which result the Turkish lira to depreciate against the euro.  [6]   After conducting Turkey the floating exchange rate system had lost more than 50% of the Turkish lira value. Therefore the lira appreciated in the mid of 2002; however their sensitivity fluctuated in the exchange rate. After this appreciation, the lira depreciated again due to the Iraq crisis. On the other hand the Turkey government takes some action to prevent the lira and its economy from certain events such as switching to formal inflation target regime. On 2006 the central bank implemented the formal inflation target and it used the interest rate as a short instrument which was the result to depreciate the lira again.  [7]   Forex rate system used in US: As a matter of fact, the U.S mainly went through two different exchange rate regimes. The first referred to what is commonly known as the Bretton woods system of fixed exchange rates and this has been the period from 1958 till 1973. However, after that period and until this day the exchange rate regime is referred to as the managed floating .The first, which lasted effectively from December 1958 to March 1973, was the Bretton Woods system of fixed exchange rates. In the second, which began in March 1973 and has continued to the present, exchange rates have been subject to managed floating which is characterized by fluctuating exchange rates on a daily basis however they are affected by the intervention of the U.S central bank in order to stabilize their currency by buying and selling their own currency. Turkish Lira history: First lira Turkish lira is the currency of turkey that is subdivided into 100 Kurus. Turkish liras symbol is TL and according to the international standard its code is TRY. Turkish lira had experienced many difficulties and changes in its history. To begin with, the Bimetallism system was adopted in turkey between 1881 and 1884. Bimetallism refers to the fact that the country functions on a double standard in other words both gold and silver were used. According to turkey at that time: 1 lira = 519 grams pure gold = 99.8292 grams pure silver  [8]  . Then, the classical gold standard was adopted in turkey from 1881 until the 1914. Gold standard means that under this particular standard the exchange rate between any two currencies will be determined only by their relative gold contents.  [9]   However this system vanished and the gold lira was worth nine lira money. As a result, and after all those changes that took place in turkeys monetary system, they pegged to British pound, then to French France, and finally to U.S.A dollars  [10]  . Second lira:- After all the difficulties in January 2005 six zeroes has been deleted from the lira currency and the Turkish lira generally became the official currency and unit of payment in turkey. The categories of liras book notes were 1, 5, 10, 20, 50, and 100. In addition the coins Category were 1, 5,10,20,50,100.  [11]   As a matter of fact, a lot of countries drop zero(s) from their currency in order to facilitate their transactions and avoid any mistakes. Dropping six zeroes and the effort to decline the inflation impact on the currency is a useful way for turkey to have a good reputation in its lira currency. Therefore dropping the zero from its currency had reduced the mistakes and problems that had arisen in the calculation side and record problems. In short, the transition to the New Turkish lira was necessary both for the expected positive effects on the currency, as well as for its reputation. Furthermore, the New Turkish Lira is considered also as a symbol or a sign of Turkeys determination to reduce inflation.  [12]   Turkish Lira against the U.S. Dollar during the past 5 y The below graph demonstrate the behavior of the exchange rate of Turkish Lira against the U.S. Dollar during the past 5 years, which reflects the economic situation in both countries. Table Source: Yahoo! finance (2009). TRY/USD (TRYUSD=X). Retrieved on 8-12-2009. http://finance.yahoo.com/q/bc?s=TRYUSD=Xt=5yl=onz=mq=lc Table outlining the exchange rates desired on a daily basis: In our research, we are going to study the exchange rate fluctuation between the Turkish Lira (TL) and the U.S Dollar (USD) during the period from 14 September to 4 December 2009. Our study depends on using the daily data of FX of TL against the USD and will focus on analyzing the factors and events that affect the exchange rate and interpreting the causes of fluctuation during the period of study. The exchange rates graph on a daily basis: Analysis of national and international events contributing to results we obtained from the graph: 17 September to 1 October As observed from the graph, the Turkish Lira had a downward sloping against the US Dollar starting from 17th September to 1st October 2009; this may be due to the fallowing factors and events. Events:- Turkish bond yields rose on due to worries about the countrys widening budget deficit Reduction in Turkeys GDP which has lead to the depreciation of the Turkish lira against the $U.S. Turkey seeks bids for sugar factories. Turkey is selling six factories that produce sugar to finance the global slow down economy. Turkey also trying to reduce the government control in its economy. However this event will test turkey privatization  [13]  . Factors:- September 2009 Balance of Payment Budget of the government: The current account deficit realized a huge increase by 60.5% from 558 in August 2009 to 869 in September 2009. This reflects the increase on the country expenditures over revenues that negatively affected the TL exchange rate The level of the country trade: The deficit of the goods and services increased by 18%, which is a mean of increase of TL supply over demand that is reflected negatively on the TL exchange rate, and put a pressure on the TL to depreciate against US Dollar.  [14]   US inflation decreased from -8.90 in June to -9.90 in September. Therefore US $ appreciated over the TL. Turkeys industrial production fell by 8.6% in the year to September. The biggest decline was in the production of capital goods, the output of which fell by 18.2%.  [15]   1 October to 15-October:- During this period our graph direction went up due to the below factors and events Events:- In October 2009 the annual meeting of the World Bank held in Istanbul, this was the fist time the meeting being held in a country other than the United State. The country outlook rating of Turkey outlook has been upgraded by the two rating agencies Moody and Standard Poors. In addition to that, there is a strong probability to upgrade Fitch rating agency of the Turkey outlook rating. This is due to Turkeys policies in handling the financial crisis and its ability to implement policies to stabilize the economy.  [16]   Factors:- Inflation: the Central Bank of the Republic of Turkey decreased the inflation rate from 5.27 in September to 5.08 in October 2009. This is considered a positive indicator that leads investors to invest in TL, consequently, TL appreciated. We can observe that the Turkish Lira firmed in October than its performance in September against the US dollar and this was due to the fact that the central Bank of Turkey stated that the annual inflation in October would be low despite the end of stimulus tax cuts on durable goods and a near 10 percent hike in power prices. 16 October to 28 October:- During this Period our graph has a downwards sloping due to the below factors and events. Factors:- Interest rate: a Central Bank of Turkey lowered its interest rate from 7.75 in September. To 6.75 in October 2009. As a result the TL depreciated ay the beginning of October reflecting the expectations of the investors that the currency will have downward direction. Budget: Finance minster of Turkey stated that Turkey end-2009 budget deficit of 62.8 billion lira ($43.1 billion) before a fall to 50.1 billion lira in 2010 which affect TL negatively. 29 October to 8 November: As the Graph show the TL lira appreciate in this period due to some factors and events. Events:- As reported in Turkey newspaper four officials at the tax office were suited for damages caused by the record tax office the case was brought by the media group. Factors:- Oil: the crude oil prices went up on November 2009 this is in indicator that investors shift their investment from dollars to oil leading dollars prices down, accordingly TL appreciated against US dollars. US dollar: Federal Reserve on Wednesday 5th November offered a caution economic outlook and kept borrowing costs near zero as a result the US dollar depreciated and the TL appreciates. The Turkish bank Turkey Ekonomi Bankasi have reach 47 % rise of profit which leads to upward TL sloping . 9-Novamber to 25 November The graph illustrate that the TL has been depreciated in this period for those factors and events. Factors Financial stability report: the CBRT has published the financial stability report, the report indicates that Turkey economy would notice a slow improvement, and in banks profitability levels in 2010 would decrease. According to the report the consumption levels is expected decline which will lead to lower the investment expenditures. This news has affected the public confidence in the economy of turkey and resulted in a decline of the TL exchange rate. Unemployment rates: According the Hurriyet Turkish news paper unemployment rate problem would still grow and would not be solved anytime soon. This is also a negative indicator that TL value will decline. US Gross Domestic Product: The third quarter economy statistics of the US have been published on 24 November 2009, it shows that the US GDP has increased at an annual rate of 2.8%, this increase in US GDP is a result of the positive contributions from personal consumption expenditures (PCE), exports, private inventory investment, federal government spending, and residential fixed investment that were partly offset by a negative contribution from nonresidential fixed investment. As a result USD gained more confidence and rose against the TL. 26 November to 30 November As the graph shown in this period the TL has a downward slop which is the most negatively sloping at the analysis period of our project. Events:- From 27 to 30 November Turkey government and business sector had a public holiday to observe the occasion of Eid Al Adha. The economy during this period slow down and this caused the downward of the TL exchange rate against the USD. The global crisis has hit turkey trade especially turkey exports to neighborhoods decrease to 7.7 % as publish in Hurriyet Daily News and Economic. EU to ask Turkey to adopt a more European Iran policy The European Union welcomes Turkeys stabilizing role in the Middle East but feels uneasy with its Iran policy,  [17]   Factors Oil: Oil price decreases on 25 of November which attract investor to buying oil by dollars as a result the TL depreciate. Inflation: in November the turkey inflation rate increases from 5.08 on October 2009 to 5.53 in November which lead to depreciate the TL in this time. Balance of trade: Turkey balance of trade increase from -2573.0 to -3948.0 deficits which mean that turkey import increase in November increasing the supply of TL which leads to downward TL. 1 December r to 4 December:- As we observe after the deep down wards at the end of November the TL appreciate at the beginning of December leads to upwards slopping. Events:- Turkish news has announced that Turkish lender Sekerbank has signed a deal loan with the international finance cooperation to finance the agriculture and foods project that worth 30 millions. Turkey news has announced that turkeys poverty rate has decreased from 17.79 percent in 2007 to 17.11 percent in 2008which leads to strong Turkish lira reputation. Factors Gold : the gold price increase from 1054.00 on November to 1115.40 on December as a result the investor shift their investment direction to invest more in safe assets which is gold leading to supply the market by dollars as result the dollars depreciate and the TL appreciate . Government Budget: the Turkey government budget has 989.80 surpluses on December after having a budget deficit for the past month. As a result the TL appreciated. Current Account : the current has increase from -863.0 on September to 671.0 on December which mean the export is greater than import and the demand of TL is greater than supply leading appreciate TL on December 2009. Conclusion:- In conclusion, we have benefitted a lot from this study as we were able to analyze the Turkish lira exchange rate against the U.S Dollar as both economies have many factors and events affecting this exchange rate phenomenon such as gold reserves, balance of payments of each country, unemployment rates in addition to inflation rates, crisis in other countries, as well as many other implications .Furthermore, As for the exchange rates instability during the past three months as was required for us to analyze, the Turkish-dollar exchange rates observed several highs and lows which was generally due to multiple political, economical, social factors, and fiscal monetary policies by both countries the U.S and Turkey. We benefitted a lot from conducting this research study as it gave us the knowledge of relating the international and national events with the currency performance along with understanding the role of the exchange rate system applied in analyzing the appreciation as well as de preciation of the currency. References: ANKARA Anatolia News Agency. (2009). Crisis hits trade relations with neighbors. Retrieved on 8-12-2009. http://www.hurriyetdailynews.com/n.php?n=crisis-hits-trade-relations-with-neighbors-2009-11-30 ANKARA Bloomberg. (2009). Fitch lifts Turkish outlook, poised to upgrade rating. Retrieved on 14-11-2009. http://www.hurriyetdailynews.com/n.php?n=fitch-lifts-turkish-outlook-poised-to-upgrade-rating-2009-10-27 ArticlesBase.com (2005-2008). Export Import in Turkey. Retrieved on 14-11-2009. http://www.articlesbase.com/ask-an-expert-articles/export-import-in-turkey-1219667.html ASIM ERDÄ °LEK. (, 2009). How vulnerable is Turkey to an external financial shock?. Retrieved on 10-11-2009. http://www.todayszaman.com/tz-web/columnists-137712-how-vulnerable-is-turkey-to-an-external-financial-shock.html Bankim Chadha, Eswar Prasad. (1997). Real exchange rate fluctuations and the business cycle: Evidence from Japan. International Monetary Fund. Staff Papers International Monetary Fund, 44(3), 328-355. Retrieved December 15, 2009, from Research Library. (Document ID: 22542091). Burak Sansal ( 1996-2009). Turkish Economy. Retrieved on 14-11-2009. http://www.allaboutturkey.com/economy.htm Bureau of Economic Analysis is an agency of the U.S. Department of Commerce.(2009). Gross Domestic Product (GDP) and Corporate Profits. Retrieved on 3-12-2009. http://www.bea.gov/newsreleases/national/gdp/gdpnewsrelease.htm Burka Sansal (1996-2009). New Turkish Lira. Retrieved on 8-11-2009: http://www.allaboutturkey.com/ytl.htm CBS Interactive Inc.(2009). U.S. exchange rate policy: Bretton Woods to the present includes glossary. Retrieved on 8-12-2009. http://findarticles.com/p/articles/mi_m4126/is_n11_v76/ai_9153142/ Central Bank of the Republic of Turkey. (2009). Balance of Payments Statistics. Retrieved on 14-11-2009. http://www.tcmb.gov.tr/yeni DÃÆ'-NDÃÅ" SARIIÃ…Å ¾IK (2009). EU to ask Turkey to adopt a more European Iran policy. Retrieved on 8-12-2009. http://www.hurriyetdailynews.com/n.php?n=eu-to-ask-turkey-to-adopt-a-8216more-european-iran-policy8217-2009-11-25 Eun Resnick (2009), International Financial Management. McGraw Hil Exchange-rates.org. (2009). 1 Turkish Lira (TRY) to Dollars (USD) Retrieved on. 6-10-2009. http://www.exchange-rates.org/history/USD/TRY/T Forex-Here.com. (2009). Turkish lira grows on growing risk appetite. Retrieved on 14-11-2009. http://www.forex-here.com/node/128 Global Futures Forex (2009). GLOBAL FOREX TRADING, WORLDWIDE LEADERS IN ONLINE CURRENCY TRADING. Retrieved on 8-12-2009. http://www.gftforex.com/resources/currency/emerging.asp IndexMundi.(2009). Turkey GDP real growth rate. Retrieved on 14-11-2009. http://www.indexmundi.com/turkey/gdp_real_growth_rate.html IndexMundi (2009). Turkey Inflation rate (consumer prices). Retrieved on 8-12-2009. http://www.indexmundi.com/turkey/inflation_rate_(consumer_prices).html InflationData.com (2003- 2009). Inflation Rate in Percent for Jan 2000-Present. Retrieved on 8-12-2009. http://www.inflationdata.com/inflation/Inflation_Rate/CurrentInflation.asp Investopedia (2009). Managed Currency. Retrieved on 8-12-2009. http://www.investopedia.com/terms/m/managed-currency.asp Investopedia (2009).Disinflation. Retrieved on 8-12-2009. http://www.investopedia.com/terms/d/disinflation.asp ISTANBUL Hà ¼rriyet Daily News (2009). Turkeys poverty rate at 17.11 percent. Retrieved on 8-12-2009. http://www.hurriyetdailynews.com/n.php?n=turkey8217s-poverty-rate-at-17.11-percent-2009-12-01 ISTANBUL Hà ¼rriyet Daily News (2009). Central Bank foresees slow, gradual recoveryRetrieved on 3-12-2009. http://www.hurriyetdailynews.com/n.php?n=the-bank-foresees-slow-gradual-recovery-2009-11-24 ISTANBUL Hà ¼rriyet Daily News (2009). Executives eye competition and innovation. Retrieved on 8-12-2009. http://www.hurriyetdailynews.com/h.php?news=executives-eye-productivity-and-2009-11-05 Joanna Stryjek(2007). Exchange Rate Regimes in the Middle East and North Africa Countries. Retrieved on 12-11-2009:http://www.arabia.pl/english/content/view/414/16/ Koà §Ãƒ §at, H.. (2008). Exchange Rates, Exports and Economic Growth in Turkey: Evidence from Johansen Cointegration Tests. International Journal of Economic Perspectives, 2(1), 5-11. Retrieved December 15, 2009, from ProQuest Central. (Document ID: 1809709051). Meyer, C., Zanetti, A.. (2008). Unit Labour Costs, the Real Exchange Rate and Swiss Competitiveness. Aussenwirtschaft, 63(1), 43-68,109. Retrieved December 15, 2009, from ProQuest Central. (Document ID: 1474657321). Online Turkey Travel Guide. History of Turkish Money. . Retrieved on 8-11-2009: http://www.turkeyforyou.com/turkey_money_history Reuters India. (2009). UPDATE 1-Turkey seeks bids for sugar factories -sources. Retrieved on 14-11-2009. http://in.reuters.com/article/oilRpt/idINLA72980020090910 Summaries of EU legislation (2008). Turkey. Retrieved on 12-11-2009 : http://europa.eu/legislation_summaries/enlargement/ongoing_enlargement/community_acquis_turkey/e01113_en.htm The Economist Newspaper. (2009). Economic and financial indicators. Retrieved on 14-11-2009. http://www.economist.com/markets/indicators/ Trading Economics.(2009). United States Current Account. Retrieved on 8-12-2009. http://www.tradingeconomics.com/Economics/Current-Account.aspx?Symbol=USD Trading Economics.(2009). Turkey Current Account. Retrieved on 8-12-2009. http://www.tradingeconomics.com/Economics/Current-Account.aspx?Symbol=TRY TURKEY: Financial crisis points to deep recession. (2008, October). Oxford Analytica Daily Brief Service,1. Retrieved December 15, 2009, from ProQuest Central. (Document ID: 1688053781). Turkish Embassy Office of the First Economic Counsellor, London. (2004-2008). ECONOMIC OUTLOOK OF TURKEY. Retrieved on 14-11-2009. http://www.turkisheconomy.org.uk/economy.html Turkish Press. (1997-2009). I Am Proud With Value of Turkish Currency, P.M. Erdogan. Retrieved on 10-11-2009. http://www.turkishpress.com/news.asp?id=253819 Wikipedia (2009). Turkish lira. Retrieved on 8-11-2009. http://en.wikipedia.org/wiki/Turkish_lira Wikipedia (2009). Economy of Turkey. Retrieved on 14-11-2009. http://en.wikipedia.org/wiki/Economy_of_Turkey Wikipedia (2009). Managed float regime. Retrieved on 8-12-2009. http://en.wikipedia.org/wiki/Managed_float_regime XE Corporation. (1995 2009). CORRECTED-Turkey Factors to Watch on Nov 5. Retrieved on 10-11-2009. http://www.xe.com/news/2009-11-05%2002:37:00.0/781409.htm?c=1t XE Corporation (1995-2009). Turkey Factors to Watch on Nov 1. 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The Battle of Bougainville :: essays research papers

The Solomon Islands campaign began with the taking of Guadalcanal in December 1942. In February 1943 the Russell Islands fell, and the New Georgia group followed in August 1943. At the end of 1943, the campaign reached its goal when American troops gained a solid foothold on the island of Bougainville. The Russells, New Georgia and Bougainville were objectives Objective: Isolate Rabaul The objective of the Solomon Islands campaign was to cut off Japan's major forward air and naval base at Rabaul, on the island of New Britain. Rabaul was the hub of Japanese air power in the south Pacific--a stopping point for planes coming from New Guinea in the southwest and Truk, the home of the Japanese Combined Fleet, in the south central Pacific. Bougainville was key to neutralizing Rabaul. Preliminary Attacks The first attack on Bougainville occurred Aug. 15, 1943. Eight Corsairs from Marine Fighter Squadron 214 (later known as the Black Sheep) flew up from the Russell Islands to strafe the Kahili airfield during American amphibious landings on the island of Vella Lavella. The lightning strike--a surprise so complete the Japanese did not have time to shoot back--damaged aircraft and refueling equipment on the ground and forestalled a night attack on the American amphibious force. because of their value as air bases. Battle of Empress Augusta Bay The evening of the landing, Army reconnaissance aircraft reported that a large Japanese surface force was heading for Bougainville. Task Force 39 intercepted it about 2:30 the following morning 45 miles west of Empress Augusta Bay. The American ships, executing maneuvers at breakneck speeds in the darkness to avoid Japanese long-range torpedoes, sank two enemy ships after three hours of heavy fire. With two other ships damaged in collisions while trying to avoid American torpedoes, the scattered Japanese chose to retreat. The American force had only two ships hit, both of which sustained moderate damage. The Japanese Response Battle of Empress Augusta Bay The evening of the landing, Army reconnaissance aircraft reported that a large Japanese surface force was heading for

The Ada and Disability Related Harassment

The Americans with Disabilities Act (ADA) and Disability-Related Harassment A Self-Advocacy Guide 3839 North Third Street Suite 209 Phoenix, AZ 85012 602-274-6287 (voice or TTY) 800-927-2260 (toll free) 602-274-6779 (fax) 100 North Stone Avenue Suite 305 Tucson, AZ 85701 520-327-9547 (voice) 800-922-1447 (toll free) 877-327-7754 (TTY) 520-884-0992 (fax) www. azdisabilitylaw. org [email  protected] org This guide was written by former University of Arizona, College of Law students: Kraig Gardner, Kevin Lira, Ryan McCarthy, Ruth Mendus, Cathy Nelson and Denise Quinterra.Funding for this document is provided by the United States Department of Health and Human Services, Administration on Developmental Disabilities and Community Mental Health Services and the United States Department of Education, Rehabilitation Services Administration. Federal and state law can change at any time. If there is any question about the continued validity of any information in the handbook, contact the Ariz ona Center for Disability Law or an attorney in your community. The purpose of this guide is to provide general information to individuals regarding their rights and protections under the law.It is not intended as a substitute for legal advice. You may wish to contact the Arizona Center for Disability Law or consult with a lawyer in your community if you require further information. This guide is available in alternative formats upon request. Revised 100307 E-8 1 The Americans With Disabilities Act (ADA) and Disability-Related Harassment TABLE OF CONTENTS A. Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 1.Scope of this Guide †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 2. The Difference Between Disability-Related Harassment and Common, Everyday Harassment. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 2 3. The Difference Between Disability-Related Harassment and Retaliation. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 2 4.Other Types of Discrimination †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚ ¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 3 B. Proving Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 4 1. Introduction †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 4 2. Elements of a Claim †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 3. Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 4 C. The Rules About Employer Liability For Disability-Related Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 8 1. Introduction. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 8 2. Owner Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 3. Supervisor Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 9 4. Co-Worker Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 10 5. Non-Employee Harassment†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã ¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 10 D. E. F. G. Duty to Employees to Avoid or Limit Harm †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 1 Employer’s Responsibility to Prevent/Stop Harassment †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 12 Steps to Take If Your Employer Does Not Take Appropriate Action †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 13 Introduction to the Americans with Disabilities (ADA) and this Guide†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 15 1. What Does the ADA Cover? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 15 2. How Does the Arizona Center for Disability Law Assist People with Disabilities? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 16 3.Why Does the ADA Include Employment Protections? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 16 4. When Do the ADA Employment Protections Apply? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 17 5. What Employers are Covered by the ADA? †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 18 H. Legal Resources†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚ ¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 19 A. Disability-Related Harassment 1. Scope of this GuideThis guide is meant to explain and describe: (1) Harassment based on disability; (2) when an employer is liable for harassment, and (3) some ways of dealing with harassment. The ADA protections described are available only to people who are qualified individuals with a disability under the ADA or who are harassed because of an association with a person with a disability (for example, a parent, son, daughter, friend, or co-worker of a person with a disability). If you are uncertain whether you are protected under the ADA, the Center has a guide that explains the meaning of the words, disability nd qualified. The title of that guide is, An Overview of the Employment Protections of the ADA. This guide is not intended to inform you about all employment-related claims, only those having to do with disability-related harassment under the ADA. This guide does not cover: à ¢â‚¬ ¢ retaliation; †¢ state law protections, such as worker’s compensation claims; †¢ tort claims related to harassment; or †¢ criminal claims related to harassment. Rasool works at a restaurant. He has a psychiatric illness. Several of his co-workers were very prejudiced and afraid of him because of his disability.To try and harass Rasool, they spraypainted his car with the word â€Å"crazy† and slashed his tires. Rasool’s co-workers may not only be harassing him in violation of the ADA, but also may have committed a crime. This guide does not cover criminal law and penalties. Report criminal conduct at the workplace to your employer. Your employer should report crimes to the police. If it does not, you should report crimes directly. Josefina has cerebral palsy. Her supervisor calls her offensive names related to her disability frequently and in front of all other employees.Josefina is humiliated and distressed by this treatment. She suffers phy sical symptoms, such as ulcers, that may be related to the treatment. Her employer may be in violation of the ADA. Josefina may have other state claims for emotional distress, including worker’s compensation. This guide does not provide information about these kinds of claims. For more information, contact a private attorney handling worker’s compensation. Visit the Arizona State bar directory at www. azbar. org for a list of attorneys specializing in worker’s compensation. 2. The Difference Between Disability-Related Harassment and Common, Everyday Harassment. The ADA was created to provide workers with disabilities a â€Å"level playing field† in the workplace. It requires employers to provide accessible facilities, to make special accommodations to the needs of protected workers, and to have employment practices that do not discriminate. The ADA also prohibits harassment based on disability, just as other federal laws prohibit harassment based on race, gender, national origin and religion.It is important to understand the difference between harassment and disability- related harassment. The law does not protect workers with disabilities, or any workers, from rude or uncivil people. The harassment must be severe and related to a person’s disability for the ADA to offer protection. Jane has a hearing impairment. She sometimes has problems understanding what people say to her. Dan is her supervisor. Dan is not a very pleasant person. He is constantly calling Jane and other workers lazy and slow. He often screams and yells when things do not go smoothly on the production line.Jane feels like Dan does not like her and the other workers. Dan may be harassing Jane in the common everyday meaning of harassment. Unfortunately, even though Dan’s behavior is not how we would like to see supervisors behave, it is not disability-related harassment. Let’s look at a situation that is very similar to the one in the first exam ple. Jane has a hearing impairment. She sometimes has problems understanding what people say to her. Dan is her supervisor. Dan is not a very pleasant person. He is constantly calling Jane and other workers lazy and slow.He also makes comments to Jane like â€Å"what’s the matter, didn’t you hear me? † and â€Å"can’t you understand anything? I thought you were deaf, not stupid. † Here, Dan’s harassment is related to Jane’s disability. It doesn’t matter if Dan is mean and rude to everyone else as well. When Dan’s harassment is severe and focuses on Jane’s disability, it is disability-related harassment. Making hostile comments is not the only form of disability-related harassment. Offensive jokes about persons with disabilities and offensive gestures and behavior can also be disability-related harassment. . The Difference Between Disability-Related Harassment and Retaliation. Another kind of treatment that is comm only confused with disability-related harassment is retaliation. Retaliation is adverse action taken against an employee because the employee (1) 2 opposed action by an employer that violated the ADA, or (2) participated in filing a formal complaint with the Equal Employment Opportunity Commission or the Arizona Civil Rights Division of the Attorney General’s Office. An employer can use â€Å"harassment† to retaliate.For example, an employer can harass an employee because the employee requested an ADA accommodation. An employer could also retaliate by harassing an employee who filed an ADA charge of discrimination when denied a promotion. Both retaliation and disability-related harassment violate the ADA. It is useful to know the difference between retaliation and harassment when you are making a complaint to the EEOC. Bob has paraplegia. He uses a wheelchair. Sue is Bob’s supervisor. Part of Bob’s job includes occasionally going to the room where the old files are stored to get these old files.Some of the files are on high shelves that Bob has trouble reaching without help. Bob asked Sue if someone else could do the job of getting the old files. Sue said no. Before this, Bob had never had any problems with Sue. Bob decided to make a request for an accommodation to the department head, who is Sue’s boss. Sue was furious. She yelled at Bob for 15 minutes and told him that if he ever went above her head again that she would â€Å"make him sorry†. She asked him to withdraw his request for an accommodation. Bob refused.During the next week, Sue began to ask Bob to do things that had never been part of his job before. She started asking him to deliver papers all over the building. Bob had no problem doing this because the building was wheelchair accessible, but it took him quite a bit longer than it would have anyone not in a wheelchair because the accessible elevator was on the other side of the building. Sue complained to Bob that he was taking too long to do these deliveries. Bob tried to explain why it took him longer to deliver the papers, but Sue wasn’t interested.Bob tried to do the deliveries faster, but Sue wrote him up when he took longer than 15 minutes. After being written up 3 times in the next week, Sue fired him. When Bob complained to the EEOC, he told them he was harassed in retaliation for requesting an ADA accommodation. 4. Other Types of Discrimination Sometimes, other types of discrimination feel like harassment. When an employer treats a person differently because of his/her disability in any of the conditions or terms of employment, it may feel like harassment.For example, if a person with a disability has been working for the company for many years and has never been permitted to go to a training to improve his skills, yet employees with less company seniority are often sent to training, this may be discrimination in the terms of employment. For more information about yo ur right as a person with a disability to equal treatment, see the Center’s guide, â€Å"An Overview of the Employment Protections of the ADA. † In addition, when an employer refuses to make changes to the work or workplace so an individual can do his/her job or enjoy the benefits of employment, it may be an unlawful failure to accommodate. For more information about your rights regarding accommodations, see the Center’s guide, â€Å"The ADA and Reasonable Accommodations. † B. Proving Disability-Related Harassment 1. Introduction The ADA does not include a specific prohibition against harassment. Most courts looking at this issue have decided that the ADA prohibits disability-related harassment because of disability because employers must prevent discrimination in the terms and conditions of employment.This means employers must prevent a hostile workplace. 2. Elements of a Claim To prove unlawful harassment under the ADA, you must be able to prove the fol lowing: †¢ you work or formerly worked for a covered employer; †¢ you are a person with a disability; with a record of a disability; or are regarded as disabled; †¢ you are or were qualified to perform your job; †¢ you faced a hostile work environment; and †¢ you were harassed by a co-worker or a third party and your employer knew or should have known about the harassment.George’s co-workers suspect he is HIV-positive because he is gay. They spray painted his locker with the words â€Å"God’s punishment† and hung plastic gloves around the office for people to use to avoid physical contact with George. George does not have HIV but he is still protected under the ADA from disability-related harassment, as he is â€Å"regarded† as a person with a disability. 3. Harassment The harassment is so severe that it changes the conditions of your employment and creates an abusive working environment or results in a tangible employment action. The conditions of your employment must change when someone harasses you because of your disability. The conditions of your employment may change because the workplace is hostile or because of an â€Å"employment action. † Either change may support a claim of harassment under the ADA. 4 Hostile Work Environment. A disability-based harassment claim under the ADA means that your workplace is so full of discriminatory intimidation, ridicule and insult toward you that it has become an abusive place to work. These claims are called â€Å"hostile work environment† claims. The ADA does not rohibit simple teasing, offhand comments and isolated incidents. To decide if the harassment is â€Å"severe† or â€Å"pervasive† enough to create a hostile work environment, courts look at: †¢ †¢ †¢ †¢ whether the discriminatory conduct has happened only once or many times; how bad the treatment is; whether it is physically threatening or humiliating; and w hether it unreasonably interferes with your ability to work. Occasional hurtful remarks by co-workers will not usually be severe enough for a successful ADA claim, unless the occasional treatment develops into a pattern of abusive treatment.Even if some co-workers refuse to talk or associate with a disabled individual, it may not be enough to support an ADA claim for harassment because courts recognize that employers cannot force employees to get along with each and every other employee. Juanita is deaf. Her co-workers ignore her and don’t try to learn any signs so she can talk to them on breaks or at lunch. It is a simple fact that in a workplace, some workers will not get along with each other. A court will usually not find â€Å"cold shouldering† enough for an ADA claim.However, in another example, Juanita’s co-workers tease her by moving their fingers at her as though they were using sign language. The co-workers pretend they are talking to her by making mou th movements just to confuse her. She is called â€Å"deaf and dumb† by people at work. Neither her co-workers or supervisor will write notes to her about important things she needs to know at work. Juanita may have a claim for disability harassment and failure to accommodate by writing notes. Generally, one instance of harassment will not amount to discriminatory changes in the â€Å"terms and conditions of employment. However, even a one-time event may be severe enough to create a hostile work environment. The standard a court uses to decide if conduct is unlawful is whether a reasonable person would find the action offensive. 5 Because of a disability, Alberto needs to use two crutches with wrist straps in order to walk. He works evening shifts as a telephone solicitor. Alberto usually sets his crutches beside his desk while he is working. One night, two co-workers decided to pull a prank on Alberto. They took his crutches nd hid them. They told the other workers what the y were up to, including the assistant manager, who was in charge of the night shift. Then they pulled the fire alarm. Alberto heard the fire alarm and looked for his crutches so that he could exit the building. His crutches were gone and he did not know the alarm was a prank. The other employees acted like they were leaving the building and exited the floor. They left him alone for 30 minutes. When he tried to crawl to the exit, they came back and laughed at him.Even though this only happened once, Alberto most likely has a claim for disability-related harassment because this conduct was so severe any reasonable person would find it offensive. Tangible Employment Action. The conditions of your employment will also change when the harassment results in an â€Å"employment action. † Harassment that results in a tangible employment action will be enough to show severe harassment. A â€Å"tangible employment action† means an important change in your employment status, not just a minor change.It usually causes you direct economic harm, and most of the time can only be caused by a supervisor or a person acting with the authority of the company. Examples of tangible employment actions may include: T firing; T failure to promote; T demotion; T a reassignment that you did not want; T a significant change in your benefits; T a decrease in your pay; T a negative change in your work assignment; T a dramatic increase in your workload; T reassignment to a position that reduces earning capacity; T reduction in hours; T refusal to grant reasonable leave requests.Javier has a severe type of diabetes. He needs to take insulin at certain times and sometimes needs to eat small snacks. He asked his supervisor for an accommodation of a 15 minute break every two hours. Shortly after the supervisor found out about Javier’s disability, she reassigned him to a different department. If Javier’s salary and benefits are the same, and the supervisor only reassig ned him because the other department already has 15 minute breaks every two hours, that probably would not be an ADA violation.However, if the supervisor told Javier that she was reassigning him because she was personally bothered by needles and did not want him taking shots in her department, that would be a tangible employment action and Javier would have a claim of disability-related harassment under the ADA. 6 The mere threat of an employment action is not enough to support an ADA claim. The harassment must be unwelcome. Jaime is deaf. He works at a department store in the shipping and receiving department. Jaime and his supervisor Erin have a professional relationship.On a frequent basis, Erin makes uninvited and offensive remarks about deaf people. Jaime has been subject to unwelcome harassment. Aheem is blind. He works at a restaurant as a cashier. Aheem and his co-worker Brian, who is overweight, are constantly making fun of each other’s conditions in a good natured w ay. One day while they are teasing each other, Brian makes a joke about blind people. Because of the nature of their relationship, Aheem has probably not been subject to unwelcome harassment.The harassment must be based on your disability, your association with a person with a disability or your request for an accommodation. The person who is harassing you must be doing it because of your disability or your need for an accommodation. It is not enough that they harass you because they do not like you or because they harass everyone. Maria is a person who has cerebral palsy. She works for a local fast food restaurant. The assistant manager is named Fred. Fred yells at Maria and the other employees frequently. Sometimes he curses.He says things like: â€Å"Hurry the ____ up! † and â€Å"What the ____ is taking you so long? † Even though most people would agree that Fred should not talk to the employees that way, unfortunately Maria will probably not have an ADA claim if t he evidence shows that Fred uses abusive language with many employees, not just Maria, and that he acts no more harshly toward Maria than he does to anyone else. This is probably not harassment that violates the ADA. However, if Fred only yells and curses at Maria and not at other employees, alls Maria offensive names like â€Å"Spaz† and â€Å"Retard†, and treats her differently than other employees, this may be harassment that violates the ADA. 7 C. The Rules About Employer Liability For Disability-Related Harassment 1. Introduction. Employers are generally responsible to provide a work place that is free of serious offenses and abuse that are based on a person’s disability. For example, employers should not permit a work place where a worker who is mentally retarded is called â€Å"retard,† is not allowed to eat with co-workers, or is subjected to co-workers’ offensive mimicking.Owners of a company, supervisors, managers, co-workers and third pa rties, such as customers, can speak or take action that creates a hostile work place. An employer is responsible for the workplace no matter who causes the hostile environment, but the courts understand that employers may not know about the harassment unless it is reported. Courts have created different rules about harassment, depending on who does the harassing. Below is a chart with examples. If the harasser is a(n): then the employer is liable for Unless the employer can show the harassment when that Owner, manager, stockholder, the harassment occurs.CEO, or president Supervisor the harassment occurs and results in a negative employment action. the harassment occurs and causes a hostile working environment Supervisor Co-worker the employer knew or should have known about the discrimination. the employer knew or should have known about the discrimination it took reasonable steps to prevent and to quickly stop harassing behavior and the employee unreasonably failed to take advantag e of the employer’s efforts to prevent or stop the harassing conduct or to avoid harm. t took immediate and appropriate corrective action. Non-employees (e. g. , customer, student, sales personnel) it took immediate and appropriate corrective action. 8 2. Owner Harassment Companies are made up of people. Some people, such as owners, CEOs, directors, and stockholders â€Å"are† the company. When people who are the company harass, the company is automatically liable for the harassment. Albert & Sons owns a restaurant that employs 40 part- and full-time employees. J. E. Albert, one of the owners, is also the restaurant manager.Lydia has worked as the Director of Catering for the restaurant for 8 years. However, she develops breast cancer and must have a mastectomy and chemotherapy. When she returns to work on a half-time basis, J. E. Albert makes numerous offensive remarks including â€Å"She’s not a real woman anymore† and speculates out loud whether  "can she satisfy her husband. † He leaves photos of well-endowed women on her desk and bulletin board. He does this frequently and over many months. It is not necessary that Lydia reported the harassment because the harasser is a co-owner. . Supervisor Harassment Because a supervisor is given direct authority over an employee, the employer is responsible under the ADA for harassment by that supervisor. An individual is an employee's supervisor if he or she: a) has the power to make or recommend employment decisions affecting the employee, and b) directs the employee’s daily work activities. Whether a harasser is a supervisor is determined by his or her job function, not his/her job title. Jim, an individual living with HIV, works in a â€Å"team† environment.His â€Å"team leader† has made several derogatory comments about Jim's illness and has even gone so far as to say that it is not worth making the effort to promote Jim. The team leader makes recommend ations regarding promotions. In this situation, the team leader is a supervisor. An employer is always liable for harassment by a supervisor if that harassment results in some sort of employment action (e. g. , firing, change in work assignment, reduction in pay or hours, etc. ) This is because an employer is responsible for the acts of its supervisors; and employers should be encouraged to prevent harassment.However, even if an employment action does not result from the harassment, an employer may be liable if the harassment creates a hostile work environment. The employer will be liable for a hostile work environment created by a supervisor unless the employer can show that: (1) it took reasonable steps to prevent and stop harassment, and (2) the employee unreasonably failed to use the employer’s steps to correct or prevent the harassment. 9 Bette supervises the nursing assistants at a nursing home. One day she sees Joe, a nursing assistant, take some medication with his lu nch.She asks him what type of medication he is taking, and he voluntarily tells her he is taking prescribed medicine to treat his bipolar condition. From that day on, Bette treats Joe badly. She calls him â€Å"crazy,† â€Å"looney,† and a â€Å"nutcase† in front of patients and staff. When things get busy at work, she asks if he is â€Å"going to crack under the pressure. † On breaks, she asks him if â€Å"he has ever had shock treatment† or â€Å"tried to off himself. † She also tells other workers she hopes he will just quit before he screws up.The nursing home is liable for Bette’s harassment unless the nursing home can show they had a complaint procedure and would have promptly stopped Bette’s harassment, but Joe unreasonably refused to complain. 4. Co-Worker Harassment An employer is liable for a co-worker’s harassing conduct if it knew or should have known of the co-worker's misconduct, unless it can show it took immediate and appropriate corrective action. Ingrid is deaf. Her co-workers often mimic her, force her to speak, and make derogatory comments about her deafness.Her work environment has become a hostile one. This situation has continued for approximately 6 months at the same level of â€Å"hostility†. Ingrid mentioned the problem several times to her shift supervisor. Ingrid's supervisor is aware of this situation and should have taken some sort of corrective action (possibly sensitivity training and discipline of offending employee), but it has not happened. Her employer is liable for the harassment by her co-workers because it has not taken any steps to correct the action. Sara is a sous chef at a restaurant.She took some medical leave for a hospitalization related to suicidal tendencies due to severe depression. When she returned to work, a small group of her co-workers had learned about the reason for her leave and began taunting her. One day, all the knives at her work s tation were hidden and a note was left that no one wanted her to hurt herself. Another instance involved a bottle of candy pills that were left spilled all over her purse. Sara reported it but the management did not investigate or take any steps to correct it. The employer is liable for the harassment. . Non-Employee Harassment An employer is liable for a non-employee’s harassing conduct if it knew or should have known of the non-employee’s misconduct, unless it can show it took immediate and appropriate corrective action. In most places of employment, there are other people who enter a workplace or are part of a workplace who are not employees. For example, a store, movie theater, restaurant or gallery will have patrons and customers. Also places of employment may have 10 independent contractors who work at the facility.For example, a hospital may employ nurses, nurses aides, medical clerks and therapists, but the doctors are independent contractors and not employees. To become responsible for the non-employee’s harassing conduct, the employer must know about it. This is because it is more difficult for an employer to be aware of all of the day-to-day events at a workplace, particularly when they involve non-employees. Jarod teaches 7th-8th graders language arts/history at a private school. The students come to believe that Jarod is gay and jump to the conclusion that he is HIV positive or has AIDS.The students spray paint offensive references to HIV in the men’s bathroom. The school did not repaint the wall for over a month and did not investigate the students believed to be involved. The school will likely be liable for the harassment caused by the students. D. Duty to Employees to Avoid or Limit Harm In general, an employee facing harassment from a supervisor (not an owner) has a duty of reasonable care. This means that as an employee, you must use all available means of prevention provided by the employer to avoid harm.Failure to do this could result in the employer escaping its legal liability or possibly being required to pay less money if there is a judgment against it. As an employee, you must be aware of the opportunities made available by your employer to employees (such as a grievance procedure) to report problems and use them if faced with workplace harassment. However, there are certain situations in which failure to use the procedures might be considered reasonable. For example, if the employee reasonably believes that: the employer does not have a complaint system that has been given out r made available to employees; Julie is a full-time cashier in a major department store. She is hard of hearing and requires the use of a hearing aid. After a month, Julie is periodically bothered by fellow employees, who poke fun at her and use her hearing impairment as a subject for their jokes and harassment. Julie wants to approach her supervisor about the situation, but is unaware of any avenues for her ha rassment complaint. As a new employee, she has not been made aware of any complaint system.There is nothing posted in the employee’s lounge or in the materials given to her by her employer. Julie’s employer has a duty to make all employees aware of the existence of a complaint system. In this instance, Julie’s failure to make a complaint would probably be reasonable. a risk of retaliation exists for those who use the complaint process; 11 Sophie is faced with harassment. She wants to file a complaint with her supervisor. However, the supervisor and the harasser are close friends. Sophie is concerned that her complaint will not be given the proper attention.The procedure does not offer any exceptions for making a complaint to someone other than a supervisor. She does not file a complaint, and the situation continues. In this case, Sophie may have acted reasonably by not filing a complaint. obstacles to complaints were present; James is autistic and cannot read or write. He works as a dishwasher. The cooks and other dishwashers make fun of him. He wants to complain and tells his supervisor about the problem. His supervisor tells him he will only accept a formal written complaint and does not offer to help him write his complaint.James has not failed to take reasonable steps. the process for complaints was ineffective. Shop-Mart has a written harassment policy that is available on-line. All new employees are provided training about the complaint procedures. Anyone can come to the training room to look at the policy on-line. Jerry wants to complain about customers who taunt him and treat him badly because he is an amputee, but his store manager has a well-deserved reputation for never checking into complaints and telling people to work it out for themselves.Also, several of Jerry’s co-workers were marked poorly on their evaluation for not getting along with others after they made a complaint of harassment. Jerry is probably acting reaso nably when he does not use these procedures. Generally, it is better to put your complaint in writing so that you can later prove that you did let your employer know about the harassment by a co-worker, supervisor, or non-employee. You should also send a copy of your complaint to the owner or director of the company.However, at times there may be other reasons you might be justified in not making a complaint. For advice, call the ADA Employment Advice Line or a private attorney. E. Employer’s Responsibility to Prevent/Stop Harassment An employer has a duty to act reasonably to prevent and correct any harassment. The most effective way of exercising this duty is through an effective complaint procedure provided to all the employees in the workplace.If written and used properly by the employee, the employer can, in some cases, discourage harassment before it takes place and, in other cases, address it immediately to limit the harm. To meet its duty, an employer should establish , publicize, and enforce anti-harassment policies and complaint procedures. It is the EEOC’s position that all policies should be clearly 12 understandable and accessible to all employees in the workplace. In addition, an employer should provide extra training focusing on harassment so that all employees will be made aware of these policies.The EEOC advises that an employer’s complaint procedure should: provide a clear explanation of conduct that is against the law; assure employees who make complaints of harassment or provide information related to such complaints that they will be protected against retaliation; describe a complaint process that provides accessible avenues to make a complaint; be flexible about the format of the complaint; assure that the employer will protect the confidentiality of harassment complaints to the extent possible; make accommodations in the complaint process as needed for people with disabilities (e. . , large print policy for visually i mpaired employee; an interpreter to interview an employee who is deaf and complaining about harassment; provide a prompt, thorough, and impartial investigation; and assure that the employer will take immediate and appropriate corrective action when it determines that harassment has occurred. The policy should focus on the prevention of harassment. An effective policy of antiharassment provides employees with protection so that they may avoid potential harassment before it happens.The complaint procedure should also encourage employees to report instances of harassment. It should be set up to prevent employees from being intimidated by reporting these incidents. One effective method to avoid intimidation is to have employees report complaints to other employees who are outside of the direct line of command. An employee will be more willing to report harassment if he/she does not have to go through a â€Å"higher-up† who was directly involved in the incident.The policy should a lso contain information on important dates and deadlines for filing a complaint with the EEOC. Even if your employer does not have a harassment policy, you should report harassment by a co-worker, supervisor or third party to your employer. F. Steps to Take If Your Employer Does Not Take Appropriate Action Practical Tips to Help You Deal with Harassment check any materials you were given as an employee or that are available to all employees (e. g. , internet site) to see if there is a procedure for reporting discrimination and harassment to your employer; 13 f there is no procedure for reporting complaints, see if there is a procedure for reporting any problems and use it; keep a journal of what has been done to you, by whom, when, how often, where and how this affected your ability to do your job; be specific about the harassment that occurred; even if you are not sure whether the misconduct is offensive enough to be unlawful ADA harassment, you can still report it. It gives your e mployer a chance to stop offensive conduct before it becomes unlawful. alk with a trustworthy friend or a hotline for support†¦problems at work can be hard to live through, and sometimes it can seem like you're imagining things; if you are not afraid of the harasser, talk to the offender and tell them the behavior is offensive and keep notes of this conversation (and date them); talk to your supervisor or another person in authority and tell them what's happening; put your complaint in writing; use the ‘legal' words defined and explained in this guide so your employer will have a clear idea of what you are requesting; and send a copy of the complaint to the management or owner of the company.Keep in mind that in most cases of harassment (except by owner, CEO, director, etc. ), the employer is not liable unless he/she knew or should have known about the harassment. This means that in general it is a good idea for employees to report the harassment to the company. If there is a complaint procedure for reporting harassment, you should use the procedure to notify the company. Get Legal AdviceOne way to get brief legal advice is to call the Arizona Center for Disability Law at 1800-927-2260 (toll-free statewide) or at (602) 274-6287 in the Phoenix area, to an experienced advocate or attorney who can provide you with information about the protections of the ADA. If you want more information, you may request copies of the Center’s self-advocacy guides about the employment protections of the ADA and sign up for a free legal training in Tucson or Phoenix. Information about the guides and training is available at www. zdisabilitylaw. org. The Center can also provide you with lists of attorneys who practice employment law in Tucson and Phoenix. File a Charge of Discrimination You can also file a charge of discrimination with the U. S. Equal Employment Opportunity Commission (EEOC). â€Å"Charges† are complaints of discrimination. You can do it im mediately or wait until you have first complained to your employer. The EEOC will investigate your charge and determine whether there is reasonable cause to believe 14 discrimination has occurred.It will then issue a right to sue letter in all cases (except for the few selected cases in which it will file a lawsuit). In Arizona, the Civil Rights Division of the Arizona Attorney General's Office (ACRD) will also take your charge. You do not have to pay to file a charge with these offices. You can call (800) 669-4800 (voice) or (800) 669-4820 (TTY) for the EEOC or (520) 628-6500 for the ACRD in Southern Arizona. You must file a charge with the EEOC or the ACRD to be allowed to bring a lawsuit for employment discrimination based on disability.You have 180 days to file a charge under state law and up to 300 days to file under federal law. For more complete information about filing a charge, please see the Center's guide â€Å"How to Enforce Employment Rights under the Americans with Di sabilities Act. † Before you go to the EEOC or ACRD, please read the guide. G. Introduction to the Americans with Disabilities (ADA) and this Guide 1. What Does the ADA Cover? On July 26, 1990, the ADA was passed by Congress. The ADA provides major civil rights protection to individuals with disabilities.The intent of this federal law is to reduce barriers to persons with disabilities and provide equal opportunity in employment, public accommodations, public services, transportation, and telecommunications. The various titles of the ADA affect many aspects of the lives of people with disabilities. †¢ Title I makes it unlawful to discriminate against qualified people with disabilities in employment. †¢ Title II makes it unlawful for state and local governments and their agencies to discriminate in programs and services, including public transportation. Title III prohibits discrimination in access and enjoyment of public accommodation and commercial facilities, such as hotels, motels, restaurants, professional offices, doctor’s offices, lawyer’s offices, convention centers, stores, banks, museums, parks, schools, and recreation facilities. Title IV requires accessibility of telecommunication services to hearing impaired persons and other individuals with disabilities. Title V provides for recovery of legal fees and establishes a mechanism for technical assistance.Additionally, Title V includes a provision prohibiting either (a) coercing or threatening or (b) retaliating against the disabled or those attempting to aid people with disabilities in asserting their rights under the ADA. †¢ †¢ 15 2. How Does the Arizona Center for Disability Law Assist People with Disabilities? If you believe you have been discriminated against on the basis of a disability in employment or access to public services, public accommodations, public transportation or telecommunication services, staff at the Arizona Center for Disability Law can prov ide you with information about the ADA and enforcing your rights under the ADA.The Arizona Center for Disability Law is a non-profit, public interest law firm providing fee advocacy, information and referral services, legal research, community legal education, and, in selected cases, legal representation to individuals with disabilities and advocacy organizations throughout Arizona. The Center is the designated protection and advocacy (P&A) system providing services for Arizonans with a wide range of physical and mental disabilities. Assistance is provided for disability-related issues in established priority areas. Information about the eligibility requirements and priorities are available from the Center upon request.Assistance is provided according to program eligibility requirements, priorities and staff availability. This Guide is Not a Substitute for Legal Advice! The Arizona Center for Disability Law recommends that persons obtain professional legal advice to resolve a legal dispute regarding discrimination on the basis of a disability. This guide is not a substitute for legal advice. This guide is meant to provide people with disabilities with information and examples about employment protections under the ADA. The information in this guide is based in part on court cases interpreting the ADA.Courts in the various parts of the country interpret the ADA differently. Not all of this information may be true for people living outside of Arizona. 3. Why Does the ADA Include Employment Protections? Oftentimes, people with disabilities do not have an equal opportunity to work or advance in their employment. People with disabilities are often restricted in employment opportunities by many different kinds of barriers. Some face physical barriers that either make it difficult or impossible to get into and around a workplace or to use work equipment at the site.Some are excluded because they communicate differently than their co-workers. Still others are excluded because of rigid work schedules which do not permit flexibility for people with special needs because of a disability. In other cases, people are not denied opportunities because of actual barriers, but because of prejudice. These are the barriers in other people's minds: fears, stereotypes, presumptions and misconceptions about job performance, safety, absenteeism, costs or lack of acceptance by coworkers and customers. 16Congress enacted the ADA to eliminate these barriers to equal opportunity in employment. The ADA makes it unlawful for an employer covered by the law to discriminate against applicants and employees with disabilities. The United States Equal Employment Opportunity Commission (EEOC) is responsible for enforcing this law. People with disabilities also have the right to bring private lawsuits against employers who discriminate against them if they first file a charge of discrimination with the EEOC within the time limits set out by the ADA.See the Center's guide, Ho w to Enforce Your Employment Rights Under the ADA, for more information about how to file a charge. However, the U. S. Supreme Court recently ruled that private individuals may not sue state employers for money damages under the ADA. Individuals may still file charges of discrimination with the EEOC against their state employer for other relief, such as court orders to stop discrimination. The U. S. Government can still file lawsuits against states for violating the ADA.The list of guides available through the Center about employment rights under the ADA include: O An Overview of the Employment Protections of the Americans with Disabilities Act (ADA) The ADA and the Job Applicant The ADA and Reasonable Accommodations The ADA and Drug Testing How to Enforce Employment Rights Under the ADA The ADA and Medical Examinations The ADA and Confidentiality of Medical Information Taking Action–How to File a Charge When You’ve Been Treated Unfairly by an Employee Because You Have a Disability How to Ask Your Employer for an Accommodation That You Need Have you been Treated Unfairly at Work?O O O O O O O O O 4. When Do the ADA Employment Protections Apply? The ADA does not cover every employment situation between an applicant and an employer or an employee and an employer. For the ADA to apply to an employment arrangement, each of the following has to be true: †¢ the employer is covered by the ADA; †¢ the employee or applicant has a disability according to the ADA; †¢ the employee or applicant is qualified to perform the job; and †¢ the employer discriminates against an applicant or employee on the basis of disability. 17For more information about each of these requirements, see the guide, An Overview of the Employment Protections of the ADA. 5. What Employers are Covered by the ADA? The ADA applies to private employers with 15 or more employees. †¢ Includes employment agencies and labor unions. †¢ Includes a location or facilit y of a business with less than 15 employees whose total number of employees for the company in all locations and facilities combined equal 15 or more. Other laws may apply to persons with disabilities who are employed by smaller businesses.For more information, contact the Arizona Center for Disability Law or a private attorney. †¢ The ADA applies to state and local governments. Includes all state and local governmental agencies, departments and entities regardless of their size or number of employees. Although the ADA applies to state employers, the U. S. Supreme Court recently ruled that employees (and applicants) can not sue state employers in court for money damages. Individuals can still file charges of discrimination with the EEOC against their state employer. Individuals can still sue to require state employers to take action or stop discriminatory action.The U. S. Government can still file lawsuits against state employers under the ADA. Examples of state and local emplo yers include: public schools, public universities, police and fire departments, public libraries, museums, public parks and recreation facilities, and social welfare offices. The ADA does NOT apply to the federal government. The ADA does apply to employees of the U. S. Senate. However, generally if a person with a disability works or applies for a job with the federal government, a federal agency, or a fully owned U. S. Government corporation, then the ADA does not apply.However, the Rehabilitation Act of 1973 is another anti-discrimination law that offers employment protections. For more information about that law, contact the Arizona Center for Disability Law or an EEO officer of the federal agency where you work or a private attorney. Title I (Employment) of the ADA does NOT apply to Indian Tribes. Tribes may have their own affirmative action or anti-discrimination laws which may address discrimination on the basis of disability. Some tribes have adopted tribal laws or entered in to agreements to abide by federal discrimination laws similar to the ADA. 18 †¢