Battle of Contreras - Mexican-American War - Battle of Padierna - Winfield Scott

Battle of Contreras - Conflict Dates: The Battle of Contreras was fought August 19-20, 1847, during the Mexican-American War (1846-1848). Armies Commanders United States Major General Winfield ScottMajor General William Worth8,500 men Mexico General Antonio Lopez de Santa AnnaGeneral Gabriel Valencia5,000 men Battle of Contreras - Background: Though Major General Zachary Taylor had triumphed in a series of victories at Palo Alto, Resaca de la Palma, and Monterrey, President James K. Polk decided to shift the focus of the American war effort from northern Mexico to a campaign against Mexico City. Though this was largely due to Polks concerns about Taylors political ambitions, it was also supported by intelligence reports that an advance against Mexico City from the north would be exceptionally difficult. As a result, a new army was formed under Major General Winfield Scott and instructed to capture the key port city of Veracruz. Coming ashore on March 9, 1847, Scotts command moved against the city and captured it after a twenty-day siege. Constructing a major base at Veracruz, Scott began making plans to advance inland before yellow fever season arrived. Moving inland, Scott routed the Mexicans, led by General Antonio Là ³pez de Santa Anna, at Cerro Gordo the following month. Pressing on, Scott captured Puebla where he paused to rest and reorganize through June and July. Resuming the campaign in early August, Scott elected to approach Mexico City from the south rather than force the enemy defenses at El Peà ±Ãƒ ³n. Rounding Lakes Chalco and Xochimilco his men arrived at San Augustin on August 18. Having anticipated an American advance from the east, Santa Anna began redeploying his army to the south and assumed a line along the Churubusco River (Map). Battle of Contreras - Scouting the Area: To defend this new position, Santa Anna placed troops under General Francisco Perez at Coyoacan with forces led by General Nicholas Bravo to the east at Churubusco. On the west end of the Mexican line was General Gabriel Valencias Army of the North at San Angel. Having established his new position, Santa Anna was separated from Scott by a vast lava field known as the Pedregal. On August 18 Scott ordered Major General William J. Worth to take his division along the direct road to Mexico City. Moving along the east edge of the Pedregal, this force came under heavy fire at San Antonio, just south of Churubusco. Unable to flank the Mexicans due to the Pedregal to the west and water to the east, Worth elected to halt. As Scott pondered his next move, Valencia, a political rival of Santa Annas, elected to abandon San Angel and moved five miles south to a hill near the villages of Contreras and Padierna. Santa Annas orders for him to return to San Angel were refused and Valencia argued he was in a better position to defend or attack depending on the enemys course of action. Unwilling to mount a costly frontal assault on San Antonio, Scott began contemplating moving up the west side of the Pedregal. To scout the route, he dispatched Robert E. Lee, recently brevetted to major for his actions at Cerro Gordo, along with an infantry regiment and some dragoons west. Pressing into the Pedregal, Lee reached Mount Zacatepec where his men dispersed a group of Mexican guerrillas. Battle of Contreras - Americans on the Move: From the mountain, Lee was confident that the Pedregal could be crossed. Relating this to Scott, he convinced his commander to change the armys line of advance. The next morning, troops from Major General David Twiggs and Major General Gideon Pillows divisions moved out and began constructing a path along the route traced by Lee. In doing so, they were unaware of Valencias presence at Contreras. By early afternoon, they had reached a point past the mountain to where they could see Contreras, Padierna, and San Geronimo. Moving down the forward slope of the mountain, Twiggs men came under fire from Valencias artillery. Countering this, Twiggs advanced his own guns and returned fire. Taking overall command, Pillow directed Colonel Bennett Riley to take his brigade to the north and west. After crossing a small river they were to take San Geronimo and cut off the enemys line of retreat. Moving over rough terrain, Riley found no opposition and occupied the village. Valencia, engaged in the artillery duel, failed to see the American column. Concerned that Riley was isolated, Pillow later directed Brigadier General George Cadwaladers brigade and Colonel George Morgans 15th Infantry to join him. As the afternoon progressed, Riley scouted the rear of Valencias position. During this time, they also detected a large Mexican force moving south from San Angel. This was Santa Anna leading reinforcements forward. Seeing the plight of his comrades across the stream, Brigadier General Persifor Smith, whose brigade was supporting the guns that were firing on Valencia, began to fear for the safety of the American forces. Unwilling to directly assault Valencias position, Smith moved his men into the Pedregal and followed the route used earlier. Joining with the 15th Infantry shortly before sunset, Smith began planning an attack on the Mexican rear. This was ultimately called off du e to darkness. Battle of Contreras - A Quick Victory: To the north, Santa Anna, faced with a difficult road and a setting sun, elected to withdraw back to San Angel. This removed the threat to the Americans around San Geronimo. Consolidating the American forces, Smith spent the evening designing a dawn attack intended to strike the enemy from three sides. Desiring permission from Scott, Smith accepted Lees offer to cross the Pedregal in the darkness to take a message to their commander. Upon meeting Lee, Scott was pleased with the situation and directed him to find troops to support Smiths effort. Locating Brigadier General Franklin Pierces brigade (temporarily led by Colonel T.B. Ransom), it was ordered to demonstrate in front of Valencias lines at dawn. During the night, Smith ordered his men as well as Rileys and Cadwaladers to form for battle. Morgan was directed to cover the road north to San Angel while Brigadier General James Shields recently arrived brigade was to hold San Geronimo. In the Mexican camp, Valencias men were cold and tired having endured a long night. They were also increasingly concerned about the whereabouts of Santa Anna. At daybreak, Smith ordered the Americans to attack. Storming forward, they routed Valencias command in a fight that lasted only seventeen minutes. Many of the Mexicans attempted to flee north but were intercepted by Shields men. Rather than come to their assistance, Santa Anna continued falling back towards Churubusco. Battle of Contreras - Aftermath: The fighting at the Battle of Contreras cost Scott around 300 killed and wounded while Mexican losses numbered approximately 700 killed, 1,224 wounded, and 843 captured. Recognizing that the victory had unhinged the Mexican defenses in the area, Scott issued a flurry of orders following Valencias defeat. Among these were orders which countermanded earlier directives for Worths and Major General John Quitmans divisions to move west. Instead, these were ordered north towards San Antonio. Sending troops west into the Pedregal, Worth quickly outflanked the Mexican position and sent them reeling north. As the day progressed, American forces drove forward on both sides of the Pedregal in pursuit of the enemy. They would catch up with Santa Anna around noon at the Battle of Churubusco. Selected Source PBS: Battle of ContrerasBattle of Contreras: Official ReportBattle of Contreras - Map

Literary Analysis Of Hedda Gabler - 1303 Words

Hedda Gabler The play Hedda Gabler tells a dramatic but realistic story of a woman forced to live in a world that was built for men. The playwright Henrik Ibsen uses this dramatic play that he has written, to make a statement about the terrible treatment of women, and their lack of independence. We can see his statement from the very start of the play, by just looking at the title, which uses Hedda’s maiden name instead of her married name. Ibsen wants her to be portrayed as her own person, and not just as the wife of her husband. Ibsen uses many literary elements to make his point, and to help the audience understand and feel what he wants them to. The time and setting in which the play was written, as well as the realistic characters,†¦show more content†¦The character Hedda contrasts wildly with the â€Å"ideal† woman that someone would expect to meet in the 1890’s. She is very sociable and comfortable talking to men as if she might be â€Å"one of t he guys.† She is also portrayed as manipulative and cruel, and she uses the darker parts of her personality to torment others for her own entertainment. In the first act of the play she humiliates Aunt Julia by â€Å"mistaking† her hat as the maids and saying that she won’t last because of it. She later tells Brack, â€Å"I pretended I thought it was the maids (1505),† while smiling at the cruel joke she had made. She continues with this mischief by manipulating Mrs. Elvsted, and burning Lovborg’s manuscript. Ibsen also uses her husband Tessman, who has more of a â€Å"feminine† personality, to contrast with Hedda’s. We see him showing more emotion and excitement throughout the play, whereas Hedda is more closed off and disinterested. Hedda is constantly annoyed by Tessman and his need to show her off as his beautiful wife. It comes across as though she feels pestered by him, and is only with him for the sake of being married and havin g a home. These are things she is pressured into feeling like she needs to have, and not things that she actually wants. She even makes a point to correct Tessman when he says â€Å"we† when talking about their or his future, because she is not happy to be stuck in aShow MoreRelatedA Literary Analysis of Hedda Gabler1618 Words   |  7 PagesA Literary Analysis of Hedda Gabler Hedda Gabler is a text in which jealousy and envy drive a woman to manipulate and attempt to control everyone in her life. The protagonist, Hedda, shows her jealousy in her interactions with the other characters in the play, particularly with Eilert Loveborg and Thea Elvsted. Because Hedda is unable to get what she wants out of life because of her gender and during the time of the play, her age, she resorts to bringing everyone else down around her. Hedda letsRead MoreHedda Gabler : The Quest For Equality3270 Words   |  14 PagesHedda Gabler: The Quest for Equality Hedda Gabler was written by Henrik Ibsen, a Norwegian playwright who focused heavily on individual freedom, along with cultural impact, and more specifically the middle class. The play was originally published in 1890 and premiered in Germany a year later. Hedda Gabler provides its audience with a stimulating theme that is frequently debated, along with dramatic dialogue and distinct realism. Ibsen’s descriptive use of stage directions presents an accurate portrayalRead MoreHenrik Ibsen s Hedda Gabler Essay2029 Words   |  9 PagesRobert Lam Prof. Blair English 1B December 2016 RESEARCH PAPER: HENRIK IBSEN’S â€Å"HEDDA GABLER† Part 1: Henrik Ibsen Henrik Ibsen was born on March 20th, 1828 and grew up in a Norwegian coastal town of Skien, as the oldest of five children. 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Ryan Adams Gold free essay sample

Is it fate that the first single off Ryan Adams Gold is New York,New York, or that its video was shot in front of the New York skyline onlyfour days before the terrorist attacks? And is it fate that the album coverfeatures Adams standing in front of an American flag? Fate or not, these factorscombined with airplay on MTV and radio have garnered much attention for Adams inrecent months. And, from the sound of Gold, this attention is welldeserved. Ryan Adams was already well-known in the indie rock community asthe frontman of Whiskeytown, one of the leading bands of the alt-countrymovement, or alt-rock bands who brought country influences into their music.After their break-up, Adams released Heartbreaker in 2000 thatimpressed audiences with his anguished, heart-wrenching song writing.Gold continues down the road with more tales of lost love, but thistime there seems to be more optimism and more rock. Adams seems to put abit of everything into the mix. We will write a custom essay sample on Ryan Adams Gold or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page There is the swaggering, Southern-fried rock ofEnemy Fire, the Memphis blues of Touch, Feel, and Lose,and the bitter, snarling rock of Nobody Girl. Of course, theres alsothe ballad of Sylvia Plath and the gorgeous Goodnight,Hollywood Boulevard. The result is an emotional roller coaster. InFirecracker Adams declares: Well everybody wants to goforever/I just wanna burn up hard and bright. Hopefully, that isnt hisphilosophy for his career. At this rate, Ryan Adams is only going to become morebrilliant. From tormented relationships to the streets of New York, Adams hasseen it all. Watch out, he could very well write a song about you, too.

Jhumpa Lahari The Namesake Essay Example

Jhumpa Lahari The Namesake Essay â€Å"The Namesake† by Jhumpa Lahari is book about the family of Bengali that has to move to a new place that has different customs than they were born with. The story is mostly about Gogol (which later changes his name into Nikhil). The theme of the story mostly centered on family. How the relationship between Ashima and Ashoke is? How the relationship between the children and the parents? This family is one of a kind. They all love each other even they are different from each other. This quote, †Being rescued from that shattered train had been the first miracle of his life. But here, now, reposing in his arms, weighing next to nothing but changing everything is the second.†(pg 24) ,explain how the mother was feeling ecstatic when her first son was born and relate it to being â€Å"rescued† from a train wreck. Ashoke is ready for the great blessing that will change her life. Ever since she came to America she had been out of sorts. She is not able to adapt easily with American customs. That’s why she consider her life a â€Å"train-wreck†. But now, she noticed that a very good thing came out of it. â€Å"For the sake of Gogol and Sonia they celebrate, with progressively increasing fanfare, the birth of Christ, an event the children look forward to far more than the worship of Durga and Saraswati.†(p.64) Proves that Ashoke and Ashima love their children and able to adapt to American customs like Christmas for their children, so their children can feel comfortable at where they live. â€Å"Ashoke wonders how closely Gogol resembles himself at this age. But there are no photographs to document Ashokes childhood; not until his passport, not until his life in America, does visual documentation exist.† (p.77) Shows that Ashoke loves Gogol but wants to show him that he was once like his father but Ashoke has no proof to show him, only in his memories. So it was hard to connect with one another. â€Å"He didnt want to go home on the weekends, We will write a custom essay sample on Jhumpa Lahari The Namesake specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Jhumpa Lahari The Namesake specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Jhumpa Lahari The Namesake specifically for you FOR ONLY $16.38 $13.9/page Hire Writer

The inspection of the register should reveal the identity of the owner, the nature of his ownership Essay Example

The inspection of the register should reveal the identity of the owner, the nature of his ownership Essay Example The inspection of the register should reveal the identity of the owner, the nature of his ownership Paper The inspection of the register should reveal the identity of the owner, the nature of his ownership Paper Essay Topic: Law Land is elemental: it is where life begins and it is where life ends. Land provides the physical substratum for all human activity; it is the essential base of all social and commercial interaction. The significance of land in human affairs is therefore incalculable, although it is only in an era of global environmental threat that we slowly begin to realise how fragile and irreplaceable is the rich resource on which we so utterly depend. As one English law lord recognised, [in] the case of real property, there is a defined and limited supply of the commodity. Gray Gray, Elements of Land Law (3rd Edition, 2000) Butterworths Before the 1925 property legislation, the mechanics of conveyancing were mired by formalism and plagued with danger even for the most conscientious purchaser. On one hand, purchasers of land were faced with numerous difficulties when trying to ascertain whether any other person has rights or interests in that land. The reliance on title deeds to prove ownership of land was both cumbersome and, for the purchaser, an expensive way to prove title, especially given the multitude of legal and equitable estates that could exist. On the other hand, an owner of equitable interest in that land might find that the interest was destroyed by a simple sale to a purchaser who was unaware of its existence. To meet both of those problems, a decision was made to move towards full title registration wherein all titles and the diverse interests in land would be recorded and guaranteed by the state. It was recognised, however, that this mammoth task had to proceed in stages and that a set of transitional provisions was needed. Therefore, the Land Registration Act 1925 (LRA 1925)1 inaugurated a fundamental change in the law in England and Wales. In conjunction with the Law of Property Act 1925 (LPA 1925)2 and the Settled Land Act 19253, the LRA 1925 sought to simplify and codify. It aimed to bring certainty where there was obscurity and to bring equity where there was often inequality. The Land Registration Act 2002 (LRA 2002)4, which has replaced the 1925 Act completely, seeks to reinforce these goals and make the system fit for the twenty-first century and the electronic age. Firstly, there is a need to clarify that land in the England and Wales today is divided into two distinct types, that of registered land and unregistered land. There is a need for this as the law governing them are separate and different. Therefore, there is a need to describe what is meant by registered land. If a plot of land is described as registered, this means that title to it (that is, an estate of freehold, or leasehold) is recorded and guaranteed by the Land Registry. 5 In contrast, unregistered land is land to which title is not registered but is established by the title deeds of the particular property6. Unregistered land is now governed by the Land Charges Act 1972 (LCA 1972)7, while registered land is governed by the Land Registration Act 2002 (LRA 2002). As full title registration has yet to be achieved in England and Wales, therefore, a certain amount of unregistered conveyancing still remains. The LPA 1925 applies in full to unregistered land in the same manner as registered land. What is different is that the enforceability or rights and interests in unregistered land being those rights and interests capable of existing under the provisions of the LPA 1925 is governed by its own sets of rules and procedures. Unregistered land can be said to present a whole different problem in itself and therefore, for the purpose of this assignment, we shall focus on the law relating to registered land. The basic principle of the LRA 1925, and now the LRA 2002 which governs registered land, is that title to land should be recorded in a register and guaranteed by the state through title registration and interests in land should either be apparent on physical inspection of the land itself or noted on the Register. Registration of title replaces what were previously deeds of title and the Register should aspire to record the totality of land ownership throughout the entire country. Essentially, this encourages and effects a shift from unregistered to registered land. The original 1925 timetable called for full registration of all land by 31 December 1955, but regrettably, only on 1 December 1990 did all of England and Wales become subject to compulsory registration of title8. It will be a while longer before near universal registration of title is achieved, but currently, over 85 per cent of all potentially registrable titles are in fact registered9 and the LRA 2002 does much to encourage voluntary first registration by owners of unregistered land by way of extending the situations which trigger compulsory registration, low fees for voluntary registration and the introduction of incentives10. It cannot be stressed enough that the advantages of registering land are obvious and aplenty. Purchasers could buy land in the certainty that they were purchasing land suitable for their requirements because the existence of hidden burdens were minimised, and owners of interests in land, such as easements11 and covenants12, had a relatively easy and inexpensive method of ensuring that their rights survived a conveyance of the land to a third party. However, this begs the question, is this really so? How certain can a purchaser be that the land about to be purchased by him is free from any burden and encumbrances whatsoever by just inspecting the Register? Martin Dixon, in his book, Modern Land Law, 6th Edition at page 38, said that The inspection of the register should reveal the identity of the owner, the nature of his ownership, any limitations on his ownership and any rights enjoyed by other persons over the land that are adverse to the owner13. This is what has come to be known as the mirror principle. The mirror principle is one of the three fundamental principles of land registration which was laid down by Theodore Ruoff in 1963, after he was appointed as Chief Land Registrar14. This can be said to be akin to the concept of a personal identification card it is supposed to provide certain information of a particular individual such as ones home address, gender and nationality, and this information should indeed reflect that individual precisely. The mirror principle suggests that the Register should be a mirror for all the proprietary rights both estates and interests that exist in any given piece of land. Thus, the Register should amount to a comprehensive picture of the land for any prospective purchaser. Sad to say, however, that the register of title is not a perfect mirror of the title to a registered property. It is not possible to rely on entries on the Register as the complete record of everything that affects the title (per Peter Gibson LJ, Overseas Investment Ltd. v Simcobuild Construction Ltd)15. Unfortunately, the 1925 Act failed to eradicate all cracks in the mirror, instead preserving the relevance of certain interests which may override registration. These overriding interests burden registered land by operating on a superior plane to other registrable interests, binding purchasers outright and disproportionately empowering the overriding interest-holder. Under the former law, the class of overriding interests which caused the most litigation was contained under Section 70(1)(g) of the LRA 1925. This subsection protected the rights of persons in actual occupation of the land or in receipt of rent save where enquiry had been made of them and their interest had not been disclosed. The justification for having such a category of interests which exists outside the Register is that they will be discoverable on inspection. The balance between the interest of the purchaser and the objective of the 1925 legislation should therefore be struck. The difficulty with this theory is that it assumes that overriding interests are all discoverable by inspection. Before the LRA 2002, this was not necessarily true. For example, the rights of an adverse possessor were protected under Section 70(1)(f) of the LRA 1925, but there was no requirement that he should be in actual occupation. His rights might not, therefore, have been discoverable on inspection; indeed, they might not even have been known to the vendor, as in Red House Farms (Thorndon) Ltd. v Catchpole16 where the owner was unaware that the defendant was shooting fowl on its land, and Prudential Assurance Co. Ltd. v Waterloo Real Estate Inc. 17, where a neighbour took over a party wall without the owners knowledge. Moreover, when an overriding interest will take effect becomes a question to be answered. A purchaser would have inspected the property before the completion of the disposition to him, but in registered land, this disposition does not itself transfer the legal estate to him and only happens when the registration is subsequently registered at the Land Registry. This then begs the question, should overriding interests be allowed to arise during the time between completion and registration? The majority of the House of Lords in Abbey National Building Society v Cann18 decided that the critical time was the date of registration except for interests arising under Section 70(1)(g) LRA 1925 which were a special case. Their Lordships decided that the date when actual occupation should be relevant is the date of the completion of the registration. This means that all other types of overriding interests can be created, without the purchasers knowledge, between completion and registration. This situation clearly shows that the Register is not the mirror it is supposed to be. It was for this reason that Lord Bridge in the Abbey National case dissented on this point, preferring the date of disposition as the relevant date for all overriding interests (except for local land charges). The concept of overriding interests within the system of conveyancing contrasts remarkably with the effect of the LCA 1972 in unregistered conveyancing. Any registrable interest left unprotected under that Act is void against specified categories of purchasers (Midland Bank Trust Co. v Green)19 to reflect the intention of the legislature in keeping the process of conveyancing simple and in protecting the purchaser. Overriding interests protected under Section 70(1)(g) of the LRA 1925 prove to be the most difficult. This was apparent in the case of Williams Glyns Bank v Boland20 where the equitable interest of Mrs Boland was held to prevail as an overriding interest against the legal mortgagee. There was nothing to prevent Mrs Boland registering protecting her interest as a minor interest on the register. For this reason, the legislature deemed that they should be protected regardless of their appearance on the Register. Paragraph 2, Schedule 3 of the LRA 2002 requires that inquiries are made of the occupier himself and not of his solicitor or the vendors solicitor. At this point, it should be noted that interests which override on a first registration of title are contained in Schedule 1 to the LRA 2002, while interests which override on a registered disposition are contained in Schedule 3. They are both basically the same, except for the rights of a squatter, but it is slightly larger in scope for Schedule 1. Additionally, there is no restriction on the types of legal easements which will be overriding as there is in Schedule 3. The concept of actual occupation is not further defined in Schedule 3 of the LRA 2002. Case law decided on the meaning of actual occupation and gave the term a wide meaning. It could include, for example, occupation through an agent as in Lloyds Bank Plc. v Rosset21. Although the occupation must in general be continuous, a temporary absence from the property will not cause the interest to be lost, as in Chhokar v Chhokar22. A further problem with Section 70(1)(g) LRA 1925 was brought about by the case of Ferrishurst Ltd. v Wallcite Ltd. 23, where it was held that where a person who is in occupation of part only of property over which he has rights may assert those rights as regards the remainder of the property in the title of which he is not in occupation. It must be accepted that overriding interests in general represent a considerable departure from the fundamental principle that the Register is a mirror of the title. The Law Commission therefore made perfect reflection a priority, and it remained the fundamental objectives of the land registration system. The Law Commission had been working on this task for some time, but the publication of the Law Commission report No 271, Land Registration for the 21st Century a Conveyancing Revolution24 including a Draft Bill brought the process to fruition. In this report, the Law Commission strived to close the cavernous crack in the mirror. The Land Registration Bill 200125 eventually became the Land Registration Act 2002 and this statute came into force on 13 October 2003, completely replacing the LRA 1925. Consequently, the 2002 legislation attempts to reduce the effect of overriding interests, both by eliminating certain categories and by inaugurating a change in the way that we think about these important rights. The LRA 2002 can be said to achieve a reduction in the categories of overriding interests by making some of these interests registrable (leases over seven years and express easements), and by restrictions on the actual occupation provision. Rights of adverse possession have disappeared altogether as overriding interests, and an entirely new regime has been introduced for adverse possession. It must be noted, however, that overriding interests were not an accident in the 1925 legislation, and although redefined and narrowed in the 2002 Act, they remain crucial to the proper functioning of the system. They were deliberately created by the legislature and given automatic effect precisely because they should be obvious to any prospective purchaser or their enforcement is too important to depend on registration. However, here is the problem: social and judicial developments have enlarged the opportunity for the existence of overriding interests with the result that it is conceivable that a purchaser might not be able to determine whether such interests exists by inspection of the land. The most obvious example is the right of equitable ownership, stemming from Pettitt v Pettitt26, whose effect under the old Section 70(1)(g) of the LRA 1925 on an unwary purchaser was first fully appreciated in Williams and Glyns Bank v Boland27. Therefore, this difficulty concerning overriding interests was a major reason why the Law Commission recommended a reduction in their scope and effect and this has now been implemented in Schedule 3 of the LRA 2002, as explained above. It can be said that the 2002 legislation tackled much that was inaccurate, unwieldy, incomprehensible, inconvenient and downright wrong in the 1925 system. Many of its provisions deal with technical matters that, while important, establish no new principle. These are the tidying up aspects of the legislation. However, there is much that is groundbreaking or truly significant, not least the claim that the 2002 Act replaces registration of title with title by registration. More disappointingly is the existence of overriding interests which remain, and therefore continue to deny the mirror principle. The register today is not yet a perfect reflection of reality. It is clear that the mirror principle is still not fully entrenched in the England and Wales system primarily because of the existence of overriding interests. Although the LRA 2002 seeked to ensure that interests override only when they are (or should be) obvious to a purchaser conducting a reasonable inspection of the land, however, the point is this: even with overriding interests, the sensible purchaser should not be unaware of binding overriding interests. Therefore, it can be said that the 2002 Act only does so much to ensure it is not clear-cut and apparent at first inspection of the Register, and this means that it leaves no space for a purchaser to be careless or flippant when inspecting the land. For that reason, there is a need to ask the question: how then, can the mirror principle be truly effected in totality in the system of registered land in England and Wales in this present day and age? We look at the role of e-conveyancing and ask ourselves its role, and the direction it is heading towards. The mirror will only be a perfect reflection when all proprietary rights both estates and interests that exist in any given piece of land are registered on the Register. Consolation lies at the advent of compulsory e-conveyancing, promoted heavily by the 2002 Act, which envisages synchronicity of disposition and registration in land transfers. This development will render many equitable interests unprotected unless registered, despite being currently overriding upon actual occupation. Schedule 3, paragraph 2 of the LRA 2002 will then be restricted only to the protection of those occupiers interests which arise informally, through resulting or constructive trusts or through estoppel, effectively narrowing an occupiers ability to override registration. The underlying and pervading expectation that overriding interests will eventually be drawn onto the Land Register through positive registration will ultimately abolish the subsistence of occupiers unregistered and overriding interests upon a transfer of registered land which so adversely affects purchasers. Section 71 of the LRA 2002 provides for a general duty of disclosure whereby an applicant for registration of a title must disclose a range or overriding interests that affect his land so that they may be protected by registration28. E-conveyancing depends on the register being as up to date as possible and the duty of disclosure is one method by which the Register becomes more mirror-like. Therefore, it seems that that is the best way forward for the future of conveyancing and thus, it is lucid that the mirror principle does not reflect English land law today. Although the LRA 2002 is a good step forward, the mirror principle as it stands today is merely in theory, and it is flawed. However, it is hoped that with the development of the law and the future of e-conveyancing, the mirror principle will entrench itself as one of the hallmarks of English land law.

buy custom Reasons for the Decrease in Russian Population essay

buy custom Reasons for the Decrease in Russian Population essay The latest demographic statistics about the population of Russia has raised intense discussion from demographers, media and the policy stakeholders. This is particularly because of the accelerating rates of population decline that Russia is experiencing. Although this decline has been underway since the breakup of the Soviet Union that took place almost a decade ago, the recent decline is particularly alarming. Russian population decreased by approximately 4.3 million to almost 144 million in January 2002 (Kuchins 119-121). The relative speed of natural decrease and declining immigration rates in Russia seem to have increased from 1998. The general decline in Russian population has been caused by a myriad of factors. These include the poor health-care systems, alcoholism, poverty levels and unemployment factors in Russia. In order to understand the demographic realities of Russia, exploration of these variables is an essential undertaking. This paper thus seeks to discuss the reasons behind the continued decline of the Russian population. In so doing, this work will tend to focus majorly on the medical/health aspects in a bid to explain this alarming demographic trend. This will, however, be linked to unemployment levels, alcoholism, healthcare standards and poverty in Russia. The conclusion of this work will be on the projections on the prospects of change of this phenomenon in the future. Deteriorating Health and Implication on Russian Population The declining health status in Russia is in part to blame for the decrease in its population. Most demographers concede that the most genuine reason for the decline in the Russian population is the dramatic rise in mortality rates. This is more evident among the working-age men. For example, in the early 1990s, Russia registered an unusual increase in the number of deaths that mostly occurred from unnatural causes (Tulchinsky and Varavikova 497). Demographics for Russia are surprising as it indicates that by 1994, the mortality rates for the males in Russia aged between 15 and 64 years was about two times higher than it was in 1986. In fact, according to the World Population Council (WPC), Russia currently has the lowest life expectancy, especially for males, among the developed countries. This stands at 58 years. This presents the largest disparity in the life expectancy of 13.5 years when males are compared to females on the same variable, all factors held constant (Tulchinsky and Varavikova 497). The health-care system of Russia is a major contribution to the declining national population as a result of high mortality rates. This is particularly so for the deaths that is caused by preventable infections and diseases. The problems with the Russian health-care system have accumulated over a long period of time. The Soviet period was characterized by reluctance to initiate incentives towards improving the medical services. The occurrence of the changes in the health-care system of Russia set in at a time when the Russian government was ill prepared to adapt and adjust its health-care system accordingly (Uhlenberg 127). Excessive focus on ideology at the expense of development of effective goals to address the medical problems that persisted in Russia even as its health-care system became impoverished worsened the state of health-care system in the country. There was thus lack of proper investment in medical facilities and equipments that were necessary to address the medical concerns of the country. As a result, the health-care system further slumped into degradation. The health-care system of Russia remains a key contributor to the increase in mortality rates in the country (Uhlenberg 127-128). This is because in its current status, the system is too ineffective to address the medical and healthcare needs of the population. Cost cutting occasioned by the crumbled Russian economy has greatly plunged the health-care system into a mess that is complicated to clean up. Because of poor health-care system in Russia, the health status of the Russian population is on an alarming decline rate (Uhlenberg 127). Diseases that were initially thought to be controllable or can be eliminated such as diphtheria are again on the increase threatening the life of the Russian population. The Russian governments initiative to save the health-care system from financial crisis and poor services has not yielded much. For example, the decision to privatize health services only fueled the crisis. Uhlenberg (128) cited that the established compulsory health insurance that is supposed to be financed through taxes has not worked because of the high poverty levels, high rates of unemployment, and the unwillingness of Russians to pay for the healthcare services since they were already used to free healthcare services. This has rendered many Russians unable to access medical and healthcare services. In the long run, diseases and illnesses that could be prevented or treated have ended up killing many. The health conditions of the Russian rural population are deplorable and lamentable. It is very unfortunate that the annual mortality rates reported are increasing because of the poor health-care system in the countryside. Manning and Tichonova (177) reports that the rural population in Russia is more vulnerable and exposed to the risk of death because of the inaccessibility of the health facilities. The facilities that are locally available are under-equipped, under-staffed or just too expensive for the people to access healthcare. As a result, when one falls sick in the Russian countryside, the probability that such persons may die before their health issues are attended to by a medical specialist is very high. In their interview with the rural population, Manning and Tichonova (177-188) cited that only a third of the respondents had had a complete medical check between 1969 and 1989. This is contrary to the situation in the urban centres. The urban population is more able to access medical and healthcare services. Although the challenge of cost of healthcare still persists in the urban centers, the Russian urban population is less exposed to the risk of death resulting from poor healthcare compared to the ural population. Therefore, one who is sick in the village is at a higher health and medical risk than the urban population. Diseases and High Mortality rates in Russia The immediate consequence of the dilapidation of the Russian health-care system is the rise in infections and diseases. Statistics about disease infection rates in Russia are alarming and loudly voice the reasons for the declining Russian population that remains alarming. For example, approximately 15% of couples in Russia are infertile (BBC News, 2000). Another 75% of Russian women are experiencing very chronic and severe medical problems in the course of pregnancy (BBC News, 2000). These figures explain the reason for the low fertility rates in Russia. The demographic implication of low low fertility rates and high mortality rates is generally a decline in the total population. The fertility rate of Russia in 1999 was 1.17 (BBC News, 2000), (Fertility rate is the average number of children that a woman aged 15 and 49 has). This demographic equation is sadly real and sensible in Russia. Besides, Sexually Transmitted Diseases have taken a toll in Russia. These include syphilis, gonorrhea, HIV/AIDS, Chlamydia and other sexually transmitted infections (Tulchinsky and Varavikova 500). The rate of HIV/AIDS infection in Russia is estimated to be one of the highest across the globe. The vulnerable populations such as drug users, homosexuals, prostitutes, do not take HIV/AIDS tests because of the confidentiality concerns. As a result, the disease has spread and become the leading Russian killer disease. The problem is further compounded by the poor health-care system that is lacking in facilities and equipments. The public health facilities lack hypodermic syringes that are disposable. This results in repeated use of needles that are unsterilized. Tulchinsky and Varavikova (497-501) cited that many patients thus contract HIV/AIDS and other diseases and die of the same. This, too, contributes to high mortality and decline in the Russian population. The implication of a high toll of infections in Russia is unfortunate. It is unfortunate in the sense that most of these infections affect the quality of the babies that are born. This is because the health of the babies is put at risk. The infections contribute towards the high infant mortality rates in Russia. The optimism for reversal of the downward demographic trend in Russia is thus gone especially because there is no hope for fertile women in future. As infection rates continue to soar, the population in Russia continues to be put at risk of further decline. Perhaps this explains the stable decline in the Russian population (Tulchinsky and Varavikova 497). Tuberculosis is a historical problem in Russia. The rate of TB infection rose to alarming levels in the early 1990s. Fueled by poor health-care system, the former Soviet Union country has lost so many people due to TB infections. The most vulnerable populations have been the drug addicts, alcoholics, the poor and the unemployed and the inmates. Thus poor health system has promoted the spread of diseases that were initially preventable and curable. Lives have been lost and more are still at risk of dying as a result of such diseases as tuberculosis. This adds to the already soaring mortality rates and thus contributes to more decline in the Russian population. Alcoholism and the Declining Russian Population In considering the factors that have contributed to high mortality rates in Russia alcoholism and other drug abuse is listed. Increased alcohol consumption in Russia contributes to the high mortality rates of the working-age population (Uhlenberg 120). According to the studies conducted on labor related accidents and disasters in Russia, the prime cause of some of the accidents is alcoholism. The employees who work with machines often report to work under the influence of alcohol. This makes them vulnerable to accidents and incidents that are caused by omissions and commissions resulting from negligence and lack of concentration. Alcohol is responsible for the high prevalence rates of HIV/AIDS and other STIs that account for a significant percentage of mortality rates in Russia. Alcohol contributes majorly to the mortality of the Russian male population. The anti-alcoholism campaign that was launched in the early 1990s contributed to improvement of the life expectancy of the Russian male population (Uhlenberg 120-121). So serious was the problem of alcoholism in Russia that the government had to intervene to secure its population from the soaring mortality rates that were majorly a consequence of alcoholism. Uhlenberg (120) observed, as many other experts equally did, that the relatively smaller increase in the life expectancy of the Russian population in 2006 was partly because of the active campaigns launched by the government that led to a reduction in the levels of alcohol consumption. The high rates of alcoholism in Russia is to blame for the increase in cardiovascular infections that has further cut short the life of many people especially the working-age population. This further contributed to high mortality rates resulting from heart-related infections and diseases that, given the dilapidated health-care system in Russia, only worsened and sealed the fate of victims to death (Uhlenberg 120). Alcoholism has thus greatly contributed towards the demographic fiasco that Russia is grappling with. The excessive levels of alcoholism among the male Russian population further contribute to the decline in the national population given that this phenomenon directly impedes the stability of the family. The age of the male population that is addicted to alcoholism is the working-age cohort. This implies that most households are rendered unable to meet the cost of living as women struggle with bringing up children. Child-bearing is thus avoided as women shy away from the burden of bringing up large families single-handedly. Besides, excessive alcoholism also limits the reproductive health, performance and activity of the Russian male population. These factors contribute significantly to the low fertility rate that is evident in the Russian demographics. Unemployment and Decline in Russian Population Unemployment is a factor that is directly connected to the realities of the demographics of any given population. This is the fact even with Russia. Thus unemployment can be used as significant variable in the study of the factors that contribute to the steady decline of the Russian population (Marshalle 64). Unemployment directly translates to poverty and lower family income. In Russia, the greatest percentage of the population that can be assumed to be actively productive lack employment. As a result, the dependency ratio is average by figure but in reality very alarming. The men who head the households who are also expected to be the breadwinners for such households are given to chronic levels of alcoholism as a defense mechanism against the harsh reality of the poverty and unemployment levels in Russia. Unemployment rates generally relates to poverty levels or poverty index of any state. This implies that the high levels of unemployment in Russia also translates to increased poverty in Russia. The reality of this phenomenon is unfortunate but directly leads population change in Russia (Marshalle 64-65). It can be used to explain the rising levels of population decline in Russia. As households in Russia become more and more impoverished and deprived in terms of access to reliable and stable source of income, the fertility rates decline. The decline in fertility rates leads to population decline since already there is high mortality rates in Russia that is occasioned with poor health-care facilities and the surge in the spread of infectious and terminal diseases in this country. All these factors contribute to the rise of the levels of negative population change in Russia (Marshalle 64). The statistics about the status of employment in Russia is alarming. For example, in the year 2007, approximately 4.6 million Russians were officially reported to be unemployed and lacked a stable and reliable source of income. This figure rose further to 6.4 million people in the year 2009 (Marshalle 64). Besides, the quality of employment has also declined for those who can be considered to be productively employed and economically active. These rates are temporal because as more global economic challenges hit hard, more and more sections of the Russian population are rendered unemployed and become dependents. In such scenarios, no single household will bear the burden of having more than two children. Even those that can be said to be employed limit the number of children because of the fear of cost of raising up a large family. Not more than 15% of university graduates have decent jobs in their areas of specialized training (Marshalle 74). Most of these graduates and the young professionals in Russia work out of their areas of specialization because of the low income and the high levels of unemployment in Russia. These directly inhibit positive population growth from the gross national increase and other factors such as immigration. According to the International Labor Organization (ILO) young graduates in Russia keep on changing jobs from one company to another. Graduate engineers, for example, who miss decent engineering job opportunities either resort to alcoholism, other social ills or go about taking up job opportunities that hardly meet their needs. In this state of affairs, more and more prospective heads of households shy away from having large family sizes because of the cost implications of sustaining such families (Marshalle 56). The difficulty of securing a well paying job leaves most families or households very impoverished. People aged 40 years and above are finding it really hard to secure employment opportunities in Russia. This section of the Russian population is the age cohort that can be assumed by demographers to be the actively productive members of the society who have another high number of dependents (Marshalle 64-66). This explains the reason for household poverty that faces many Russian families. This economic reality conditions many potentially reproductive populations to limit the number of children that they are willing to raise. As a result, low fertility rates in Russia are to remain relatively stable as the population experiences a decline. The true picture of employment state of Russia is that there are specially trained personnel. Nevertheless, Russia faces a crisis of finding people who are ready and willing to take up the job opportunities where they work hard and get unacceptably low pays. Marshalle (64) cited that this makes many of the married couples and individuals in conjugal relationships to embrace active and consistent use of family planning methods and contraceptives to limit the risk of conception. However, this phenomenon adds to the already low fertility rates in Russia. Unemployment and poverty therefore contributes to the relatively stable pattern of population decline in Russia. Prospects for Change in the Russian Declining Population The negative change in the Russian population that ushered in a rapid decline from the early 1990s has slim chances of reversal for the better. The government population policies to enhance fertility rates and alter the relatively high mortality rates have not been very effective. The health-care system in Russia remains under-funded even in the post Soviet period. This implies that the high mortality rates in the countryside and the urban centers are not about to decline. The rise in the rate of infectious infections and diseases can thus not be altered. As a result, the Russian demographic dynamics are headed for the worse. Conclusion The Russian demographic dynamics and realities are alarming especially given the high mortality and low fertility rates. In order to change the rising decline in the Russian population, the Russian government must invest in the health-care system, development effective economic stimulus structures and programs to create more job opportunities. This will alleviate the household poverty situations in the Russian population. Improved household income will improve the reproductive and demographic realities in Russia. Buy custom Reasons for the Decrease in Russian Population essay

MTV The Leading Multimedia Youth Brand Essay Example | Topics and Well Written Essays - 1250 words

MTV The Leading Multimedia Youth Brand - Essay Example The work environment provides its employees the ability to contribute, be heard and be successful. MTV was named the world's most valuable media brand for an uninterrupted six years by Business week and Intebrands world's most valuable brands study. Its portfolio of media and entertainment can be broadly classified into online and television channel brands. Some of MTV Networks online, online interactive and web based entertainment brands include Harmonix, AtomFilms, GameTrailers (GT), Xfire, AddictingGames and Shockwave, GoCityKids, Neopets, ParentsConnect and Quizilla. CMT, Logo, MTV, MTV2's, mtvU, MTV Tr3s, MHD, VH1,VH1 Classic,VH1 Soul, COMEDY CENTRAL,Spike TV,TV Land,Nickelodeon, Nick at Nite, NOGGIN and The N are the television channel brands under the networks portfolio. The programming content of the MTV channel laid emphasis on reality shows The Real World and Road Rules during the mid- to late 1990s and early 2000s. The years 2005 and 2006 witnessed the channel returning its focus on reality television content with the debuts of popular shows such as 8th and ocean, Laguna Beach: The Real Orange County, Parental Control and the like. To attract and retain the teen and young adult viewer segment, the channel has also airing movies made for that particular age group. Several productions of its own film producing division is also being broadcast. In 2009 it added scripted comedy programs to its pprogramming portfolio With the recent downslide in the networks ratings, MTV stepped into 2009 with a massive shift in programming. It broadcast content focuses more on reality programming. "You get an intense sense of reality that you haven't seen on television before," Graden says. "These are (techniques) that are interesting that I don't see anyone else doing." Brian Graden is the President of Programming, MTV and VH1. Revenues And Profits The following excerpt taken from www.smartbrief.com gives an account of the Third Quarter 2008 financial Results of Viacom of which MTV is a unit. "Revenues grew 4% to $3.41 billion in the third quarter 2008 led by a 6% increase in Media Networks revenues with Filmed Entertainment revenues relatively flat versus the prior year's results. Operating income declined 15% in the quarter, primarily reflecting a $91 million decrease in the Filmed Entertainment segment as it lapped the strong performance of Transformers in the third quarter of 2007. Third Quarter 2008 operating income decreased 15% to $689 million versus $815 million in the third quarter of 2007. Operating income for the Media Networks segment declined 4%, reflecting the impact of lower advertising and consumer products revenues as well as higher expenses primarily related to programming.Business Outlook For the full year 2008, Viacom expects to deliver mid-single to low double-digit growth in adjusted diluted earnings per share from continuing operations.Stock Repurchase ProgramFor the quarter ended September 30, 2008, 7.6 million shares were repurchased for an aggregate purchase price of $215 million. As of October 31, 2008, the Company has $1.4 billion remaining in its existing $4 billion share repurchase program.