Abstinence Only Education and Sex Education in the U.S.

Abstinence Only Education and Sex Education in the U.S. When the Centers for Disease Control and Prevention announced in April 2012 that teen birth rates in the U.S. hit a new low in 2010 and revealed which states had the highest and lowest rates, it prompted a question: Were these outcomes affected by individual states requirements for sex education (sex ed) and/or abstinence-only education? That was soon answered by the Guttmacher Institutes State Policies in Brief paper on Sex and HIV Education in May 2012. The institute has kept the numbers constantly updated since as the trend of lowered teen birth rates has continued to drop nationwide. Required Sex and/or HIV Education Sex ed is mandated in 24 states and the District of Columbia. Of that total, the following 22 states and the District of Columbia mandate both sex ed and HIV education: CaliforniaDelawareGeorgiaHawaiiIowaKentuckyMaineMarylandMinnesotaMontanaNevadaNew JerseyNew MexicoNorth CarolinaOhioOregonRhode IslandSouth CarolinaTennesseeUtahVermontWest Virginia Two states mandate sex ed only: MississippiNorth Dakota HIV education is mandated in 34 states and the District of Columbia. Of that total, 12 mandate only HIV education: AlabamaConnecticutIllinoisIndianaMichiganMissouriNew HampshireNew YorkOklahomaPennsylvaniaWashingtonWisconsin Must Include Contraception When sex ed is taught, some states have specific content requirements. In addition to the District of Columbia, 18 states require that information on contraception be provided when sex education is taught: AlabamaCaliforniaColoradoDelawareHawaiiIllinoisMaineMarylandNew JerseyNew MexicoNorth CarolinaOregonRhode IslandSouth CarolinaVermontVirginiaWashingtonWest Virginia One state allows local schools to include contraception with the permission of the State Department of Education: Mississippi Must Include Abstinence When sex ed is taught, 37 states require that information on abstinence is provided. Of those, 26 states require that abstinence be stressed: AlabamaArizonaArkansasDelawareFloridaGeorgiaIllinoisIndianaKentuckyLouisianaMaineMichiganMississippiMissouriNew JerseyNorth CarolinaOhioOklahomaOregonRhode IslandSouth CarolinaTennesseeTexasUtahWashingtonWisconsin These 11 states require only that abstinence is covered during sex education: CaliforniaColoradoHawaiiMarylandMinnesotaMontanaNew MexicoNorth DakotaVermontVirginiaWest Virginia No Mandate There are nine states with no sex education or HIV education mandate: ArizonaArkansasColoradoFloridaIdahoLouisianaMassachusettsTexasVirginia Five of the states listed above also rank among the top 12 states with the highest teenage birth rates, and four rank in the top 6 (ranking indicated in parentheses): Mississippi (1)Arkansas (3)Texas (4)Louisiana (6)Arizona (12) An earlier report issued by the Guttmacher Institute in September 2006 compiled teen pregnancy statistics state by state. Among the top 10 states with the highest rates of teen pregnancy among females age 15-19, five are states without mandated sex education or HIV education (ranking indicated in parentheses): Arizona (2)Mississippi (3)Texas (5)Florida (6)Arkansas (10) That same report ranked the top 10 states with the highest rates of live births among teenage girls age 15-19. Again, five are states that do not require sex ed to be taught in schools. If and when it is taught, these states do not require information on contraception be provided, but they do require that abstinence be stressed (ranking indicated in parentheses): Mississippi (1)Texas (2)Arizona (3)Arkansas (4)Louisiana (7) Only one state that does not mandate sex education or HIV education appears in the listing of states with the lowest teenage birth rates: Massachusetts ranked at number 2. Sources Guttmacher Institute, State Policies in Brief: Sex and HIV Education. Office of Adolescent Health, Trends in Teen Pregnancy and Childbearing

Renaissance Artists Characteristics essays

Renaissance Artists Characteristics essays The early renaissance artists characteristics in their art were very prominent. One of the characteristics shown was a great reference to the classical art of the ancient Greeks and Romans. You can see this in Paintings by Masaccio, Fra Angelico, Francesca Fra Lippi, Mantegna and Botticelli. Some of the other characteristics can be seen in some of the art works are: In the Tribute Money by Masaccio the classical influence. You can see this by looking at the right hand side of the painting. There are Roman arches and columns in the buildings. The landscape in the background is excellently done. The depth is very obvious ass seen by the rutes receding and the perspective in the building and creating a 3d look. The use of light and the folds in the garments looks very realistic. Resurrection by Francesca. This painting can mean a lot of different tings to different people. Some people think that the people of the bottom are dead. Other people think that they are sleeping or crying. The background landscape is scattered trees, which are in front of hills. This suggests a feeling of depth. The triangular look to the painting is caused because the vision of Christ is in the middle of the painting and higher than the rest of the people. The figure of Christ is much lighter than any one else. Making this a general significant point. Overlapping shapes creates depth. This is done in the painting by the overlapping of the figure of Christ and the people in front of the podium. The modeling of the clothes is detailed. They are wearing tunics with definite emphasis on the folds. This gives the painting a 3d appearance. This is a religious based painting. Like so many others of this time. Annunciation by Fra Angelico. The perspective is not well executed although it is an attempt. The folds on the garments arent as realistic as the others, but are still d ...

Religion Essay Example | Topics and Well Written Essays - 1000 words

Religion - Essay Example he Sealing of the Servants of God who are the 144,000 and the multitude; chapters 8 and 9 is about the Altar and Prayers, the Trumpets, and the Woes; chapter 10 is about the Mighty Angel and the open sweet bitter Book; chapter 11 discusses The Temple and the Two Witnesses; chapter 12 is about the Woman and the Dragon, the Church, and the 7 battles lost by Satan; chapter 13 is about the Two Beasts from sea and earth and the Antichrist; chapter 14 speaks of the Triumph of Christ with the 144,000, the Condemned and the Harvest; chapter 15 is about the Victorious, the Victory over the Beast; chapter 16 is about the 7 Last Plagues (or 7 Bowls, 7 Cups, 7 Vials); chapter 17 talks of the Woman on the Beast and Babylon, the Great Harlot; chapter 18 talks of the Doomed City, Babylons complete fall; chapter 19 deals with Armageddon, the King of kings on the white horse, the quadruple Alleluia and the Marriage Supper of the Lamb; chapter 20 discusses the Millennium and the Great White Throne Jud gment; chapter 21 deals with the New Jerusalem and the New heaven and New Earth; and chapter 22 talks of the New Jerusalem and the River of Life (Dominguez 2006). Bible scholars have different interpretations of the Book of Revelations. Some say it is a description of the difficult times that the Israelites were going through during the Old Testament and ends with the birth of Christ. On the other hand, some scholars say it is about the journey that the New Testament Christians are going through beginning with Christ’s birth until His final return to take the believers with Him. What ever is the standpoint of these Bible scholars, the fact remains that as seen through the themes of each chapter of the Book of Revelation there is a pattern of a flow of events from dark to light. The dark times represent the difficult times and the light is the hope that finally someday all these trials will come to an end and that happiness will at last be attained for â€Å"He will wipe every tear

Contract law Essay Example | Topics and Well Written Essays - 1000 words

Contract law - Essay Example Churton and Silver were able to inform Risk It of the situation, who agreed to amending the loan agreement by postponing the payment of the principal due for 1 year, and waived all interest payables. However, due to financial problems of its own, risk It now wishes to enforce the original loan agreement against Churton and Silver, and the latter refuses citing the limitations on what they may pay and the ill effects full payment would do in damaging their business enterprise. Prior to formulating the legal advice, I would present to Risk It, it is important to first outline the various legal concepts. In the case at bar, there is clearly a contractual obligation, voluntarily undertaken by both parties. Commonly this is considered a bilateral contract, which imposes upon both parties certain obligations that they agreed upon. Here, Risk It agreed to loan the money to Churton and Silver, who in turn agreed to pay the loan based on the agreed terms. Although the facts make no mention as to the manner in which Risk It agreed to amending the terms of payment of the loan as per the difficulty in financial situation of Churton and Silver, there is really no difference as to whether or not the agreement to amend the terms is in writing or not. Despite common sense, contracts can be legally binding even if not reduced into writing, and have the same effect as if it were on paper. Thus, the acts of Risk It in agreeing to change the terms of the loan is binding upon them, and they can no longer renounce that change or deny it otherwise. This is a key concept of contract law, that contracts are formed through an agreement consisting of an offer and acceptance, a valuable consideration, and the intention of the parties to create a contract. Further assuming that all the necessary requisites of a valid contract are also present in the case at bar, there is no need to delve into the complexities of the form, parties' capacity to contract, consent freely given, and legality of the subject matter or purpose of the contract. Seeing as this is a clear contract of loan, all things should be in order. With all that said, it is clear that the only advice I can make to Risk It is for them to follow the amended loan agreement that they had made with Churton and Silver. The changed terms, and waived interest became binding on them from the moment it was made, offered and accepted by the parties. They can no longer renounce or go against that agreement, or they put themselves at risk of legal suit for the remedies due to breach of contractual obligations by Churton and Silver. It is necessary to state that the remedies for breach of contractual obligations include the award of monetary damages by the courts and a petition for specific performance. The former is the assessment of monetary sum to be given by the offending party to compensate for the injury that would be suffered by the breach of contract. This could be a relief sought against Risk It if they try to enforce the original loan agreement instead of the amended one that would inevitably cause great damage and injury to the business enterprise of Churton and Silver.  

Tragedy in Death of a Salesman Essay Example for Free

Tragedy in Death of a Salesman Essay Arthur Miller depicts a salesman, named Willy Loman in the play Death of a Salesman. Faced with hardships and troubles, Willy maneuvers in ways that cause his unfortunate outcome. In the tragedy, Death of a Salesman, the main protagonist Willy Loman’s fatal flaws were his unrelenting pride and his inability to face reality, which ultimately led to his demise. This novel is a tale about the tragedy that was the life of Willy Loman. A tragedy is a â€Å"serious drama† that depicts a â€Å"conflict† between the protagonist and a â€Å"superior force† such as which ends up with â€Å"disastrous consequences† that elicits â€Å"pity†. (Merriam Webster) Death of a Salesman is a tragedy because the main protagonist is a man filled with unrealistic hopes and dreams that lead to his demise. Although the story portrays a tragedy, I believe Willy Loman attempted to find optimism in defeat. By definition, a tragic hero is â€Å"a great or virtuous character in a dramatic tragedy that is destined for downfall, suffering, or defeat.† (Dictionary.com) Willy’s life resembled that of a tragic hero, he was not one by definition because there was nothing great or virtuous about him. He was an average person who lived a tragic life. As one critic suggests, â€Å"Willy Loman is too far down the social scale to be considered a classical â€Å"tragic hero† he represents the average man.† We learn that he made mistakes just like any other human being. In fact, one of the mistakes he made changed the very way he lived his life and perceived himself. In the beginning of the story, Willy cheats on his wife and is caught by his son Biff, which negatively affects their long-term relationship. As a result, Willy always feels guilty, leading to a constant struggle between father and son about almost everything. One example of this is in Act II, after arguing Biff says to his father, â€Å"Dad, you’re never going to see what I am, so what’s the use of arguing? If I strike oil, I’ll send you a check. Meantime, forget I’m alive† (129). A lot of times they argued because Willy always wanted to see the positive even when in realit y things were not as he believed. The tragedy is that his life was full of delusions and misguided dreams. In the beginning of the story, Willy explains to his wife why they cannot leave the crowded city to live in New York They dont need me in New York. Im the New England man. Im vital in New England(4). However, as the story continues we see that Willy had a false perception of himself. In fact, he was not well liked. Instead, he was  laughed at and pitied. In actuality, his boss had wanted to fire him, but just did not have the nerve to do it. This is seen when Willy goes to his boss asking to be given a position as a floor salesman, his boss tells him, â€Å"I don’t want you to represent us. I’ve been meaning to tell you for a long time now†(83). After Willy’s life long commitment to the company, he is fired and even then, he does not wake up to the understanding that in society he is nothing special. Biff tries to make his father realize that he is nothing special by saying, Pop! Im a dime a dozen, and so are you! This infuriates Willy who counterattacks, I am not a dime a dozen! I am Willy Loman, and you are Biff Loman! Another one of Willy’s flaws was his unrelenting pride. For example, when Charley offers him a job he refuses saying he already has one even though in truth he was just fired. After further discussion Willy finally responds saying, â€Å" I can’t work for you, that’s all, don’t ask me why† (98). We see irony here because a little after this Willy is willing to ask Charley to borrow money but refuses to take a job from him. Willy Loman’s flaw was his hubris and his inability to face reality. He had the right idea just the wrong dreams. Ultimately, his unrelenting pride and his inability to face reality led him to his demise. One must acknowledge that throughout the whole story he strived to make up for his mistakes and do the right thing. He had mostly good intentions, however, he made mistakes just like any other human being. However, contrary to most people, he judged himself harshly for his mistakes and constantly criticized himself. He tried to overlook his mistakes or hide them for the rest of his life. As the play goes on, we learn that he has a hard time facing reality that is complicated by his unrelenting pride and at the same time, he suffers from self-loathing. As the play goes on and Willy’s identity as a salesman is stripped from him, we begin to understand better the importance of his life insurance policy. After Willy loses his job, which was his primary identity, he is forced to face reality that he could never be like his brother who was his hero. He could never be the father he wanted to be or thought his sons deserved. He wanted his son Biff to look up to him and excel in life. He realized that he was not the star salesman he always believed himself to be. We see this as he becomes increasingly preoccupied with his life insurance policy, which symbolizes the only other way he can provide for his family; he has been a failure at everything else.  He always had the best intentions and the play ends with Willy trying to provide for his family in the only way possible, as the critique states, â€Å"Willy of course ends the play with nothing he can sell – except himself, hoping that his expired life insurance policy will pay up.† According to Dictionary.com, the definition of a tragic hero is â€Å"a great or virtuous character in a dramatic tragedy who is destined for downfall, suffering, or defeat.† Although Willy was not a virtuous character, in the end, he tried to do what he thought was right by providing for his family in the only way he thought possible. His life was tragic because he tried to cope by living in denial about his failures. In the end, he faced reality in the only way he thought he could, by taking his life. Works Cited 1. Miller, Arthur, and Gerald Clifford. Weales. Arthur Miller: Death of a Salesman, Text and Criticism. New York. Penguin, 1996. Print. 2. Tragedy. Merriam-Webster. Merriam-Webster. Web. 09 Apr. 2012. . 3. Tragic Hero. Dictionary.com. Dictionary.com. Web. 08 Apr. 2012. . 4. Literary Criticism Attached

Death Of Christ Essay -- essays research papers

The Death of Christ EXAMINATION   Ã‚  Ã‚  Ã‚  Ã‚  I chose to look into Jesus death and the people who were involved in it. The first group of people who got hold of Jesus was the Roman soldiers. They were probably the most innocent in the whole thing. Granted they did perform the actual act of crucifying Christ, but it was because of the order that Pilate gave them. As I looked into crucifixion and how it started I found that before Jesus was crucified, more than 30,000 men, in Israel alone, had already been crucified. It all started by this guy named Ormazd from Persia. He thought that the earth was sacred, so he did not want to defile the earth by killing criminals on it so he put them on a large pole and left them there to die. After Pilate gave the order to crucify Christ the soldiers took him. The part of their wickedness was not the act of crucifying Christ, it was by what they did to Jesus before they crucified him. The scripture says in Matthew 27, that the soldiers, â€Å"gathered a full Roman cohort around Him.† I looked into what a â€Å"full Roman cohort† was. It seems that a total of 600 soldiers make up a full Roman cohort. I also learned that Jewish people were given the right not to be in the Roman military. I also fount out the cohort was traveling around with the governor as a military escort. Because of that it is pretty safe to say they never heard of Jesus, other than the fact that He was being crucified because he was claiming to be some sort of king.. The soldiers knew that he claimed to be a king so they stripped him down and put a scarlet robe on him. Next they took thorns and thistles and weaved a crown together and put it on Jesus head. My understanding is that Caesar wore a wreath on his head and the soldiers were mimicking Him. As they put the crown of thorns on Jesus head blood ran down on Jesus face, which made him even more unrecognizable. The final piece of dress that the soldiers put on Jesus was a reed in his right hand. The way John MacAuthur, Jr. explained the reed was that it was to represent royalty, authority, and power. After giving Jesus the reed the soldiers were making fun of Jesus by getting on their knees and pretending to worship Him. They then took the reed from his hand and beat Jesus on the head with it while they were saying this like, â€Å"Look how easy we strip you of your power and authori... ...sense? My next biggest thing would be the knowledge of what is wrong but giving into the flesh. I guess that would be what the people standing around the cross were doing.   Ã‚  Ã‚  Ã‚  Ã‚   It might seem a little weird but I kind of want to be like the Pharisees. Not what they did but what they know. This paper has pushed me just a little closer to that and I’m pretty happy with the outcome and cant wait until I can use what I have now learned in real life. Douglas, J.D. The New International Dictionary of the Christian Church. Publisher House,1978 MacArthur, John The MacArthur New Testiment Commentary Library of Congress in Publication Data, 1989 Tenney, Merrill C. The Zondervan Pictoral Encyclopedia of the Bible Zondervan Publishing House, Douglas, J.D. The Illustrated Bible Dictionary Part 2 Inter-Varsity Press, Cross, F.L. The Oxford Dictionary of the Christian Church Oxford University Press, 1968 Green, Joel B. Dictionary of Jesus and the Gospels Inter Varsity Press, Bible translations used: NIV, The Message, New Living, and New American Standard The Death of Christ Death Of Christ Essay -- essays research papers The Death of Christ EXAMINATION   Ã‚  Ã‚  Ã‚  Ã‚  I chose to look into Jesus death and the people who were involved in it. The first group of people who got hold of Jesus was the Roman soldiers. They were probably the most innocent in the whole thing. Granted they did perform the actual act of crucifying Christ, but it was because of the order that Pilate gave them. As I looked into crucifixion and how it started I found that before Jesus was crucified, more than 30,000 men, in Israel alone, had already been crucified. It all started by this guy named Ormazd from Persia. He thought that the earth was sacred, so he did not want to defile the earth by killing criminals on it so he put them on a large pole and left them there to die. After Pilate gave the order to crucify Christ the soldiers took him. The part of their wickedness was not the act of crucifying Christ, it was by what they did to Jesus before they crucified him. The scripture says in Matthew 27, that the soldiers, â€Å"gathered a full Roman cohort around Him.† I looked into what a â€Å"full Roman cohort† was. It seems that a total of 600 soldiers make up a full Roman cohort. I also learned that Jewish people were given the right not to be in the Roman military. I also fount out the cohort was traveling around with the governor as a military escort. Because of that it is pretty safe to say they never heard of Jesus, other than the fact that He was being crucified because he was claiming to be some sort of king.. The soldiers knew that he claimed to be a king so they stripped him down and put a scarlet robe on him. Next they took thorns and thistles and weaved a crown together and put it on Jesus head. My understanding is that Caesar wore a wreath on his head and the soldiers were mimicking Him. As they put the crown of thorns on Jesus head blood ran down on Jesus face, which made him even more unrecognizable. The final piece of dress that the soldiers put on Jesus was a reed in his right hand. The way John MacAuthur, Jr. explained the reed was that it was to represent royalty, authority, and power. After giving Jesus the reed the soldiers were making fun of Jesus by getting on their knees and pretending to worship Him. They then took the reed from his hand and beat Jesus on the head with it while they were saying this like, â€Å"Look how easy we strip you of your power and authori... ...sense? My next biggest thing would be the knowledge of what is wrong but giving into the flesh. I guess that would be what the people standing around the cross were doing.   Ã‚  Ã‚  Ã‚  Ã‚   It might seem a little weird but I kind of want to be like the Pharisees. Not what they did but what they know. This paper has pushed me just a little closer to that and I’m pretty happy with the outcome and cant wait until I can use what I have now learned in real life. Douglas, J.D. The New International Dictionary of the Christian Church. Publisher House,1978 MacArthur, John The MacArthur New Testiment Commentary Library of Congress in Publication Data, 1989 Tenney, Merrill C. The Zondervan Pictoral Encyclopedia of the Bible Zondervan Publishing House, Douglas, J.D. The Illustrated Bible Dictionary Part 2 Inter-Varsity Press, Cross, F.L. The Oxford Dictionary of the Christian Church Oxford University Press, 1968 Green, Joel B. Dictionary of Jesus and the Gospels Inter Varsity Press, Bible translations used: NIV, The Message, New Living, and New American Standard The Death of Christ

RE: Letter to the editor Essay

In reply to your letter, I would like to inform you, that the policy regarding the removal of Aboriginal children was not as you stated. As soon as a child was born, they were considered a ward of the state because of their Aboriginality. The policy of Assimilation was established in 1911 for the removal of children from their community to extinguish their culture. This is also known as Genocide, but was not seen that way until the policy was removed in the mid 1960s. Bessy Flower was born in 1943, and taken from her home at 19 months. She was a product of the Assimilation policy. Bessy was removed just the same as most of the other children, pulled obscenely from her mothers arms. She was placed to live in the Annesfield native institution for the next 14 years of her life. Just the same as most of the other Aboriginal children in the homes, she was no longer allowed to make any contact with her family and was subjected to ongoing physical, mental and sexual abuse, malnutrition and humiliation. In some of the institutions the standards of living were degrading just so that the children could have an education and become ‘absorbed’ into the white community, some say it was as if they had been tried to be turned a ‘different shade of white’. The half-caste children were taken under a legislation, which gave guardianship to the protectors in their state of origin. The people that looked after the children once they were removed, once called ‘protectors’, took up the role of paternalism. This gave the parents no right to appeal to the court of law, and the children had no choice in what they did or where they went. After 1940 the children were removed under the general child welfare legislation, but still the way the children were extracted was much the same  as before. Only very gradually did the ritual of separating half-caste children from their homes meet with the general non-Aboriginal practices concerning child abuse and neglect. This came as late as the 1970s, when already tens of thousands of children had been removed. The reason the children were removed was always thought to be for their own benefit, to protect them from themselves, as well as to ‘breed-out’ the Aboriginal race as it was thought that they were less-superior to white people. Some people remember; â€Å"†We were told that our mother was an alcoholic and that she was a prostitute and she didn’t care about us. They used to warn us that when we got older we’d have to watch it because we’d turn into sluts and alcoholics, so we had to be very careful. If you were white you didn’t have that dirtiness in you †¦ It was in our breed, in us to be like that.†Ã¢â‚¬  Although now, there is thought to be not one Aboriginal family that has not been scared by the removal of a child, sibling, niece or nephew. Somewhere between one in three and one in ten children were removed. One in ten is a big number of people to be subjected to the abuse endured, but one in three is preposterous. Some of these children were taken at birth, some at two years of age, some in their childhood years. When the children were removed, they were given a chance at an education that they would never have gotten otherwise. Not all of the children had a horrible up-bringing; some were placed into homes and treated with respect from their foster families. â€Å"†We were all happy together, us kids. We had two very wonderful old ladies that looked after us. It [Colebrook, South Australia] wasn’t like an institution really. It was just a big happy family. Y’know they gave us good teaching, they encouraged us to be no different to anybody else.†Ã¢â‚¬  These children have called themselves the ‘Stolen Generation’. Although all  the State governments in Australia have apologized for the injustice that went on, the Federal Governments still refuse the Aborigines right to an apology or compensation. Bibliography: http://72.14.203.104/search?q=cache:NldOa-78ca0J:www.ondix.com/pdf/docs/studies_research_college_1071167943.pdf+bessy+flower+1943+assimilation&hl=en&gl=au&ct=clnk&cd=2 Told a story that helped with the insight to the cruelty of what really went on in some people’s lives as an affect of assimilation. http://www.tim-richardson.net/misc/stolen_generation.html Explains clearly the Assimilation policy, and the legislations surrounding it. http://www.hreoc.gov.au/bth/additional_resources/bth_guide/children_experiences.htm Gave some quotes form people that were removed who grew up with good lives, and bad. Documentary watched with Mrs. Hooks class can’t remember what it was called, but it had people explaining just how much they suffered, even when they had a good life to find out what really happened and where their family might have been for the past 70 years. More informative than internet sites because they were proper interviews.

Change of Position Defence

The defendant may claim the defence of change of position. Whether the defendant can successfully establish this defence depends of whether he can prove that his position is so changed that he will suffer an injustice if called upon to repay or repay in full (Lipkin Gorman v Karpnale) * In order to prove a change of position defence, first there must be an adverse change of position by the recipient in good faith and in reliance on the payment (New Zealand Banking Group v Westpac Banking Corporation) * The current position in Australia with regard to the availability of the defence is that the defendant must have (1) changed their position (2) irreversibly (3) in reliance on its receipt (4) in good faith (Australian Financial Services)(1) CHANGE THEIR POSITION / SUFFER DETRIMENT * The defendant must first be able to prove a change in the relative net assets of the defendant which shows that the defendant has acted to his detriment on the faith of the payments received from the plaint iff. In other words, the change must involve a net loss.FACTUAL GAIN BUT NET LOSS * Even where a woman who had purchased new furniture and had got rid of her old furniture on reliance on her receipt, where the court accepted that she was factually enriched by her receipt since her net assets were worth more than what she had before, the change of position defence would nevertheless apply since if she was required to make restitution, she would be left with a net loss. * The mere fact that she continues to benefit from the money does not defeat the defence of change of circumstances. The furniture acquisitions represent replacement of items the plaintiff had in her possession when she would not have replaced the items except for the error. The expenditures were not to meet ordinary expenses or pay existing debts.(RBC Dominion Securities v Hills Industries)IS SPENDING ON ORDINARY LIVING EXPENSES CHANGING YOUR POSITION? In general, expenditure on ordinary living expenses will not be re garded as a detriment or that the defendant changed his position because the defendant has to prove that he acted differently from how he would have ordinarily acted on the faith of the belief that the benefit conferred by the plaintiff was the defendant’s to spend (Australian Financial Services & Leasing v Hills Industries) * However, a defendant is not precluded from relying on the defence of change of position merely because she has spent the money on ordinary living expenses, provided the expenditure is a substantial detriment stemming from her reliance on receipt of the payment. The defence can apply where the defendant does not simply spend the money on such expenses but applies for and is denied benefits to which she is entitled as a result of her receipt (TRA Global Pty Ltd v Kebakoska) In that case, the respondent had been made redundant by her employer who told her she was entitled to a redundancy payment equivalent to 12 weeks pay on severance and accordingly p aid her the sum. She in fact had no such legal entitlement.She subsequently applied for unemployment benefits from Centrelink but was denied them because she had declared receipt of the redundancy money. She was forced to used the bulk of the redundancy money to pay living expenses until she found work eight months later. When the appellant employer sought restitution of the payment on grounds of mistake, the court held that the plaintiff had a defence of change of position despite having spent the money on ordinary living expenses since the expenditure is a substantial detriment stemming from her reliance on receipt of the payment and was denied benefits to which she was entitled as a result of her receipt.DISCHARGING AN EXISTING DEBT * It is not a detriment to pay off a debt which will have to be paid of sooner or later (RBC Dominion Securities v Dawson) In that case Mr Dawson had a Visa debt which he liquidated in a manner he would not have otherwise done had it not been for the mistake on the part of the appellant to overpay him. However, since the Visa debt and those to family members was incurred prior to the mistake, it would have been paid in any event and cannot be said to be to Mr Dawson’s detriment because the payment would be a payment of a debt already owed. (2) IRREVERSIBLY * The second element is that actual, non-speculative and irreversible detriment (Australian Financial Services & Leasing v Hills Industries) The nature of the change must be such that it cannot now be undone such as money received which has been irretrievably paid away or incurring unconditional contractual obligation as a result of receipt. In Australian Financial Services, the plaintiff finance company was duped by a fraudster and two of his companies into advancing money to several legitimate businesses including that of the second defendant to whom the fraudster and his companies owed money so as to discharge their debts. The plaintiff was led to believe that th e purpose of the money being advanced to the defendants was to finance the purchase of equipment they were supplying to the first company when the equipment never existed. Each of the defendants was accustomed to receiving payments for their equipment from finance companies so they were not immediately suspicious of receiving money from the plaintiff.The plaintiff then claiming unjust enrichment against the defendants on the ground that it had made payments under the mistaken belief that the invoices made by the fraudster to the plaintiff, purporting to be from each of the defendants, were genuine and that it would obtain title to the equipment named in the invoices. * In this case, the court held for the defence of change of position to succeed that there must be evidence of an irreversible detriment. The second defendant having foregone default judgments already obtained against one of the fraudster’s companies was in reliance on receipt of the money from the plaintiff was such evidence. * In TRA Global Pty Ltd v Kebakoska, the detriment to the plaintiff such that she was denied benefits to which she was entitled to stemming from her reliance on receipt of the payment was irreversible. In RBC v Dawson, the fact that the purchased new furniture and had got rid of her old furniture on reliance on her receipt would have caused her in the circumstances a loss that is unjust for her to bear and which is not easily reversible. * Thus it seems that the defendant must show at the very least, significant hurdles to getting the money back. (3) In reliance on the receipt/on the faith of receipt * This third element shows that there must be a causal correlation between the detriment suffered and the receipt of the payment. A BUT-FOR TEST IN UK * The mere fact that the recipient may have suffered some misfortune is not a defence unless the misfortune is linked at least on a but-for test with the mistaken receipt (Scottish equitable) There a variety of conscious de cisions which may be made by the recipient in reliance on the overpayment.A CAUSAL CONNECTION IS SUFFICIENT IN AUSTRALIA – ONE CAUSE * In Co-Buchong v Citigroup Pty Ltd, it was held that for the purposes of a change of position defence, a payment is made ‘on the faith of the receipt’ if it is causally linked to the receipt. This requires that the payment would not have been made unless the receipt has been recognised as valid. There is no further requirement that the information upon which the payer was acting be such that, if it were true, the payer would have been entitled to pay the money away in the way that id did. * In this case, Citibank had received instructions purporting to be from the plaintiff to transfer 500,000 from his account to a second account in his name at the NAB.Citibank examined the instruction and determined that it was genuine and paid. NAB then received similar instructions to pay the money away to various overseas bank accounts. Here th e instructions were all forgeries perpetrated by an unknown third party. Citibank claimed restitution of its payment to NAB on grounds of mistake. The issue was whether NAB was entitled to a defence of change of position and whether those payments had to various overseas bank accounts had been made ‘on the faith of its receipt’ of the money from Citibank. It was held that NAB did make those payments on the faith of its receipt and all that was required was a causal link between the payment and the receipt. The fact that a third party fraudster had instructed the bank to make out the payments should not necessarily negate the causal connection between the receipt and its payment so as to defeat the defence (rejecting State Bank v Swiss Bank Corporation) * In such a case, the bank’s good faith receipt may still be a cause of a change of position even if it was not the only cause and this should be enough. * This follows the reasoning in the NSWCA case of Perpetual Trustees Australia Ltd v Heperu. Perpetual had paid away sums to Mrs Cincotta funds represented by the units credited on the faith of the receipt of payments by the respondent who had been induced by fraud to do so.The respondents submitted that Perpetual had not proven that the payments of funds out of the account were made on the faith of the receipt because it paid out the funds represented by the account on the faith of what it was told to do by Mr Cincotta in the original forgery of Mrs Cincotta’s signature at the opening of account and in telephone redemptions. * This was construed to be far too narrow an analysis of what is meant by â€Å"on the faith of the receipt†. Payments on the faith of the receipt meant that they would not have been made unless the receipts had been recognised as valid. Just because there was the element of dishonesty of Mr Cincotta which also was the occasion for the withdrawal of funds, this did not negate the causal connection between the receipt and the payments. The change of position remain causally linked to the receipt. Thus while the test seems to involve a causation element, this is not a but for test but rather that the payments of the money were caused or linked to the receipt of payments from the plaintiff. ANTICIPATORY EXPENDITURE – DOES IT COUNT? * Can a defendant be said to rely on the faith the receipt when there is anticipatory expenditure on the part of the defendant? * Can reliance be understood as something other than an essentially causal concept where the effect of the defendant’s expenditure follows the cause which is the defendant’s receipt of the enrichment? Or does it mean that the defendant can be said to have acted on the faith of the receipt where it had a reasonable expectation of receipt? * In the case of Dextra Bank, Dextra Bank drew a cheque on its bankers, Royal Bank of Canada in favour of the Bank of Jamaica.Dextra drew its cheque intending to lend the sum spe cified to the Bank of Jamaica against the security of a promissory note executed by the Bank of Jamaica. The Bank of Jamaica intended to buy the specified sum of US dollars in exchange for the equivalent in Jamaican dollars which it paid to individuals understood to be nominated by Dextra. Dextra sued BOJ for restitution of the moneys paid. BOJ claimed that it had the defence of change of position. However Dextra argued that BOJ was relying on actions performed by BOJ before it received the benefit from Dextra and this amounted to anticipatory reliance which could not amount to a change of position. The issue was thus whether anticipatory reliance on the plaintiff’s payment can amount to expenditure on the faith of the benefit of the payment and thus whether an effective change of position defence can be made out. * It was held that it is no less inequitable to require a defendant to make restitution in full when he has bona fide changes his position in the expectation of rec eiving a benefit which he in fact receives, than it is when he has done so after having received the benefit.The court thus held that there should be no effect on the availability of the change of position defence whether the payment is made when the benefit is received or on a reasonable expectation that it is to be received. Anticipatory expenditure can be recognised as payments made on the faith of the benefit of the receipt. This was also recognised in South Tyneside v Svenska Internation where the court held that it does not follow that the defence of change of position can never succeed where the alleged change occurs before the receipt of money, as seen from the facts of Lipkin Gorman where the defence succeeded despite the winning being paid out before getting other gambling bets in. * In Commerzbank, the court held that the relevant question in whether the change of position defence would succeed was whether his decision to change his position was caused or contributed to b y the receipt of the payment. The crucial point the courts have emphasised is the causal relationship between the detriment and the receipt and not the strict when the detriment and the receipt or occurred. 4) In good faith * The defence is not open to a recipient who had changed his position in bad faith as where the defendant has paid away the money with knowledge of the facts entitling the plaintiff to restitution (Lipkin Gorman) * What is crucial to the good faith element is whether the payee had actual knowledge of all the facts constituting the wrongdoing or else had knowledge of such facts as would reasonably raise a suspicion of wrongdoing so that the payee was put on enquiry (Mercedes-Benz v National Mutual Royal Savings Bank Ltd) * Does a person act in good faith unless he acts dishonestly? (Niru) * NO. A person can act in bad faith where the recipient knows that the payer had paid the money to him as result of a mistake of fact or mistake of law and it will in generally b e unconscionable or inequitable to refuse restitution. Just because he is not guilty of dishonesty does not make him innocent. Will knowledge of the mistake bar the defence? * Waitaki- mere knowledge of the fact that the money is not due probably doesn’t bar the defence if d acts reasonably: d knew that the money was not its money to keep and in fact put the money on deposit, ready to repay. D was allowed the defence (albeit partially) when the money was lost through the collapse of the company with whom the sum had been deposited, even though it knew about the mistake when it put the money on deposit. * Lipkin Gorman: In cases where the payee had grounds for believing that the payment may have been made by mistake but cannot be sure, good faith may well dictate that an enquiry be made of the payer.The nature and extent of the enquiry called will of course depend on the circumstances of the case but I do not think that a person who has good reason to believe that the payment was made by mistake will often be found to have acted in good faith if he pays the money away without first making enquiries of the person from whom he received it. * English courts to date appear generally more relaxed about defendant fault, although they have tended to be thinking about fault with regard to the initial receipt of the money (â€Å"should defendant have known about the error†? ), as opposed to fault with regard to what is then done with it. * Whether fault is relevant to good faith? * In both Dextra and Niru, the CA aid that the defendant will only be denied the defence if he was in bad faith when paying away the money * The way the CA in Niru defines bad faith actually comes quite close to a negligence standard – acting in a â€Å"commercially unacceptable way† or with â€Å"sharp practice falling short of outright dishonesty†. If negligence in not realising the mistake is insufficient to bar the defence, then it seems unlikely that negl igence in a decision about how to dispose of the money will be. Also, it would seem strange if a good faith payment to charity could give rise to the defence, but a good faith (but negligent) investment couldn’t? * A different approach is taken in NZ . In Waitaki, fault is relevant. The facts are that the defendant received 50,000. He takes the money and puts it into an investment with the finance company which eventually goes under.The bank then realises they paid him the money under mistake and sue him. * The defendant had relied on the receipt because the bank had forced him to take it. However he had never thought it was valid. The court held that the defendant had partly been at fault in the ultimate loss of the enrichment because he had chosen an insecure investment. Where defendant failed to obtain sufficient security for a risky investment, he had defence reduced by 10%. This introduces the uncertainties of the â€Å"contributory negligence† model of COP, which requires a relative balancing of the fault of p and d in proportioning the amount repayable. The approach was expressly rejected in Dextra as being â€Å"hopelessly unstable†.DEFENDANT WHO ILLEGALLY CHANGES HIS POSITION AS A WRONGDOER * Recently suggested that a defendant who changes position illegally is a ‘wrongdoer’ cannot invoke the defence (Barros Mattos) * The recent case of Barros Mattos now indicates this is highly likely to be the case. In reaching this conclusion, Laddie J drew support from Lord Goff’s ‘wrongdoer’ limitation in Lipkin Gorman: this indicates that defendant can be disqualified from the defence either because of his knowledge of the claimant’s rights before changing his position, or because the change of position itself is â€Å"wrongful†. * Should this affect civil wrongs? This result does not specifically affect restitution for wrongs, since civil wrongs are not considered illegal as such.Despite the co ncept of ‘illegality’ by its very nature being hard to define, it is clear from both Tinsley v Milligan [1994] 1 AC 340 and Nelson v Nelson (1995) 184 CLR 538 that it relates to claims which would run seriously counter to public policy. In Lipkin, Goff suggested that COP should not be open to wrongdoers, but it is not clear that he was referring to those guilty of an innocent breach of duty. DEFENDANT WHO INDUCES THE MISTAKEN PAYMENT IN THE FIRST PLACE * Deliberate: No defence- Goff in Lipkin Gorman- defendant will be in bad faith and bad faith precludes reference to the defence. Note that it is assumed in Niru that dishonesty is sufficient to amount to bad faith, even if it is not always necessary.It is clear from Niru that dishonesty amounts to bad faith, even if defendant can sometimes be in bad faith even where there is no actual dishonesty. * Negligent: No clear authority on this. Defence probably still available, but not if it amounts to â€Å"bad faith† as defined recently in Niru. There, defendant was denied defence on the basis that it had documents in its hands which were forgeries, which it ought to have realised might be forgeries and into which it had failed to make reasonable inquiries. This amounted to failure to act in a â€Å"commercially acceptable† way, tantamount to bad faith and denying the defendant access to the defence, even though defendant was not dishonest in the sense of appreciating the risk of fraud.It is arguable that in the light of Niru, plaintiff would be in a strong position to argue that the defence should be denied to defendant here on the grounds that defendant’s inducement was not â€Å"commercially acceptable† behaviour. * Innocent: Defence probably still applicable, since, if inducement was â€Å"innocent† in the sense of being non-negligent, it might be commercially acceptable behaviour, as per Niru. DOES THE DEFENCE ACT AS A COMPLETE DEFENCE? * No it can apply pro tanto. (Australian Financial Services & Leasing Pty Ltd v Hills Industries) * Meaning you give back to the extent of what you still have. * How does this compare with estoppel? * Estoppel by representation remains available as a total defence to restitutionary claims even in circumstances in which the defence of change of position is available.Properly understood, it does not undermine the defence of change of position as they are based on different elements. In estoppel, one had to prove representation and detrimental reliance. Whether one can plead estoppel however depends on how equitable it is for to make such a claim to the overpayment received. In TRA Global, the court held that equity may intervene to prevent the latter’s unconscientious assertion in certain circumstances. It may be inequitable to assert a full defence of estoppel when you are overpaid 1000 and remain in possession of 500 which was mistakenly paid to you. * Under a defence of change of position, your ent itlement will be 500. |

Dialogue Guide Definition and Examples

Dialogue Guide Definition and Examples In reported speech, a dialogue guide serves to identify the speaker of directly quoted words. Also known as a dialogue tag.  In this sense, a dialogue guide is essentially the same as a signal phrase or a quotative frame. Dialogue guides are usually expressed in the simple past tense, and they are customarily set off from the quoted material by commas. In the context of small-group communication, the term dialogue guide is sometimes used to refer to a facilitator of group discussions, or to a booklet that provides advice on fostering communication between individuals. See Examples and Observations below. Also see: DialogueDirect SpeechQuotationTom Swifty Examples and Observations Its a polite Chinese custom to show you are satisfied, explained my father to our astonished guests.(Amy Tan, Fish Cheeks. Seventeen magazine, 1987)Im here, she said, because Im a taxpayer, and I thought it was about time that my boys have a look at those animals.(Ralph Ellison, On Being the Target of Discrimination. The New York Times, April 16, 1989)Look at these, the man from Kentucky said, holding up a rib. You could take these home and use them to make a skeleton.(Susan Orlean, Lifelike. The New Yorker, June 9, 2003) â€Å"He doesnt want Dijon, he  insisted, waving the waitress off. Here- he shoved a yellow bottle of Frenchs mustard in my direction- heres some mustard right here.(Barack Obama,  The Audacity of Hope.  Crown/Three Rivers Press, 2006)Never, said Elie Wiesel, never shall I forget that night, the first night in the camp, which has turned my life into one long night, seven times cursed and seven times sealed.We gotta call the newspaper, a doctor said.No, Werner said. He looked straight ahead, not at any of them. I just want you to sew me up.(Jo Ann Beard, Werner. Tin House, Fall 2006) Once Steinbrenner  said to me  before an Old-Timers Game, Get your ass down there and manage the team.†(Robert Merrill, quoted by Curt Smith in  What Baseball Means to Me. Hachette, 2002) The Function of Dialogue GuidesWe use quotation marks to identify certain material as an accurate, word-for-word report of someone elses speech or writing.  A representation of speech usually has two parts, a  dialogue guide  identifying the speaker and the quote itself: I got it down from five to three minutes, Mr. Brennan said later of his feat.(Scott Rice, From Reading to Revision. Wadsworth, 1996)   Elmore Leonards Advice on Reporting Dialogue3. Never use a verb other than said to carry dialogue.The line of dialogue belongs to the character; the verb is the writer sticking his nose in. But said is far less intrusive than grumbled, gasped, cautioned, lied. I once noticed Mary McCarthy ending a line of dialogue with â€Å"she asseverated,† and had to stop reading to ge t the dictionary.4. Never use an adverb to modify the verb said† . . .. . . he admonished gravely. To use an adverb this way (or almost any way) is a mortal sin. The writer is now exposing himself in earnest, using a word that distracts and can interrupt the rhythm of the exchange. I have a character in one of my books tell how she used to write historical romances full of rape and adverbs.(Elmore Leonard, Easy on the Adverbs, Exclamation Points and Especially Hooptedoodle. The New York Times, July 16, 2001) Alternate Spelling: dialog guide

History of the X-Ray

History of the X-Ray All light and radio waves belong to the electromagnetic spectrum and are all considered different types of electromagnetic waves, including: microwaves and infrared bands whose waves are longer than those of visible light (between radio and the visible)and UV, EUV, X-rays, and g-rays (gamma rays) with shorter wavelengths. The electromagnetic nature of x-rays became evident when it was found that crystals bent their path in the same way as gratings bent visible light: the orderly rows of atoms in the crystal acted like the grooves of a grating. Medical X-rays X-rays are capable of penetrating some thickness of matter. Medical x-rays are produced by letting a stream of fast electrons come to a sudden stop at a metal plate; it is believed that X-rays emitted by the Sun or stars also come from fast electrons. The images produced by X-rays are due to the different absorption rates of different tissues. Calcium in bones absorbs X-rays the most, so bones look white on a film recording of the X-ray image, called a radiograph. Fat and other soft tissues absorb less and look gray. Air absorbs the least, so lungs look black on a radiograph. Wilhelm Conrad Rà ¶ntgen - First X-ray On 8 Nov 1895, Wilhelm Conrad Rà ¶ntgen (accidentally) discovered an image cast from his cathode ray generator, projected far beyond the possible range of the cathode rays (now known as an electron beam). Further investigation showed that the rays were generated at the point of contact of the cathode ray beam on the interior of the vacuum tube, that they were not deflected by magnetic fields, and they penetrated many kinds of matter. A week after his discovery, Rontgen took an X-ray photograph of his wifes hand which clearly revealed her wedding ring and her bones. The photograph electrified the general public and aroused great scientific interest in the new form of radiation. Rà ¶ntgen named the new form of radiation X-radiation (X standing for Unknown). Hence the term X-rays (also referred as Rà ¶ntgen rays, though this term is unusual outside of Germany). William Coolidge X-Ray Tube William Coolidge invented the X-ray tube popularly called the Coolidge tube. His invention revolutionized the generation of X-rays and is the model upon which all X-ray tubes for medical applications are based. Other inventions of Coolidge: invention of ductile tungsten A breakthrough in tungsten applications was made by W. D. Coolidge in 1903. Coolidge succeeded in preparing a ductile tungsten wire by doping tungsten oxide before reduction. The resulting metal powder was pressed, sintered and forged to thin rods. A Very thin wire was then drawn from these rods. This was the beginning of tungsten powder metallurgy, which was instrumental in the rapid development of the lamp industry - International Tungsten Industry Association (ITIA) A computed tomography scan or CAT-scan uses  X-rays  to create images of the body.  However, a radiograph (x-ray) and a  CAT-scan  show different types of information. An x-ray is a two-dimensional picture and a CAT-scan is three-dimensional. By imaging and looking at several three-dimensional slices of a body (like slices of bread) a doctor could not only tell if a tumor is  present but roughly how deep it is in the body. These slices are no less than 3-5 mm apart. The newer spiral (also called helical) CAT-scan takes continuous pictures of the body in a spiral  motion so that there are no gaps in the pictures collected. A CAT-scan can be three dimensional because the information about how much of the X-rays are passing through a body is collected not just on a flat piece of film, but on a computer. The data from a CAT-scan can then be computer-enhanced to be more sensitive than a plain radiograph. Inventor of the Cat-scan Robert Ledley was the inventor of CAT-Scans a diagnostic x-Ray system. Robert Ledley was granted patent #3,922,552 on November 25th in 1975 for a diagnostic X-ray systems also known as CAT-Scans.

A biographical sketch of Johannes Brahms Research Paper

A biographical sketch of Johannes Brahms - Research Paper Example His education began in 1835 when he enrolled at Heinrich Friedrich, elementary school. In 1844, he joined a private secondary school managed by Johann Friedrich Hoffman where he conducted his studies until 1847. He loved Bach and Beethoven and his audience marveled as they watched him play the piano and even conquered that his playing of the Bach was masterful and came from the heart (Van Camp, Leonard, Ottley, Jerold 156). And by 1846, he was earning money for playing piano in some local entertainment joints. Brahms initially became renowned as a composer in the chamber of music, a fact that has made some of his critics to place him in the conservative German camp of Schumann. However, it was his inclination to write in a chamber music style while stressing on thematic-motive development, and logical forms that earned him fame as an accomplished composer of brain music. Chamber music was critical for Brahms compositional output at every level during his auspicious career (Steib 96). Brahms was self-conscious of his technical abilities and worked effortlessly to improve them (Littlewood 344). He started composing at an early age, but he was so self-critical and did not want to acknowledge his effort by putting his name on his compositions. In 1848, Brahms attended a performance by Joseph Joachim in Hamburg Philharmonic Orchestra of Beethoven’s Violin Concert though he did not meet him until 1853. In the same year, Brahms held his first own concert, where he played music composed by; Theo Dohker, Jacob Rosenhain, Marxen, Bach, and Herz. Other artists who performed at the event included Franziske Cornet-Kiel and her daughter Adele. In 1849, Brahms began to write potpourris for music journalist August Cranz under the alias G.W. Marks. The same year he held his second own concert where he performed music by; Sonata, C. Mayer while Cornet-Kiel and her daughter participate yet again. He

Movie Review on E.T. (The Extra-Terrestrial) essay Lab Report

Movie Review on E.T. (The Extra-Terrestrial) essay - Lab Report Example For those who believe aliens did crash land in America, there seems no doubt that they were visiting our planet with a purpose. This film seems to suggest the possibility that these otherworldly visitors are merely curious to learn more about the life-forms on this planet. The film opens with the landing which is more frightening for the aliens than the humans, who seem to have been expecting them. In the chaos, one young alien becomes separated from his brothers and finds himself seeking shelter from a small family on the outskirts of town. A young boy, Elliot, finds the creature, who he begins to call ET (for extra terrestrial) and lures him into his room as a safe spot using Reese’s Pieces candy. Hiding the creature from his mother, Elliot finds it necessary to eventually include his younger sister, Gertie, and his older brother, Michael, in trying to help the lonely alien return to his ‘home’, the spaceship that brought him. This is made difficult by a mother becoming increasingly concerned about what her children are doing, the friction that has developed in the family thanks to a recent separation between the mother and father and the deadly effects of a poisonous atmosphere on ETs delicate body. In addition, as time passes, a symbiotic relationship begins to develop between ET and Elliot (notice the similarities in their names) so when ET gets drunk, so does Elliot. This means when ET begins to die thanks to the atmosphere, so does Elliot. Finally, an invasion from the government, determined to run tests on the creature, brings the situation to a head as ET dies, releasing Elliot and his body is packed up for shipping to a more secure laboratory location. The isolation unit he’s placed in provides ET with the purified air he needs to heal himself, though, and the three kids, now a cohesive unit, work together to break ET out of the