Privacy Essay Example | Topics and Well Written Essays - 1250 words

Privacy - Essay Example ual’s wish to remain obscured or relatively unnoticed from the public and security which can also be achieved by privacy in reference to the protection of information. Its importance has also been an issue that has been discussed on a large scale with relevance to how important it is for the existence of privacy within the society (Wack, 2010). An invasion of privacy refers to the intrusion of ones personal matters or the revelation of information to the public that an individual would have rather kept secret or away from the public eye. This invasion of privacy is the main opponent that individuals face in the fight to withhold information that they may not want others to know. There are a number of scenarios where privacy is upheld and it does not just deal with an individual on a personal level. There are different types of privacy that ca n be considered according to the particular situation that is being faced at that particular time. The types of privacy include: Personal Privacy – This type of privacy refers to an individual on a personal level where it is one person is involved. This usually has to do with the exposure of a person’s body to others. For example, a person usually prefers to be alone in certain situations such as taking a bath or changing their clothes because they would not like a person to see them in a state of undress (Solove, 2009). This can also be referred to as personal modesty. There is also the issue of privacy in terms of living conditions and relationships with those who may live next to you. This can be seen in the walls and fences that are erected around an individual’s personal property in a bid to maintain their coming and goings private (Wack, 2010). There is also the concept of curtains that are erected on windows to prevent people from being able to see inside a house. Personal privacy has always been in existence since the formation of societies as individuals have always wanted to keep certain aspects of their

Summary response paper Essay Example | Topics and Well Written Essays - 500 words - 2

Summary response paper - Essay Example in Durham Regional Hospital where educational events were held for the purposes of instructing the hospital staff on the aims of RRT as well as the criteria for calling a rapid response. Further, the critical care unit (CCU) got trained on ways of assisting floor nurses asses and stabilize patients as well as on the means of communicating with physicians through Situation, Background, Assessment and Recommendation (SBAR) method (Critical Care Nurse, 1). After education and update of policies, the RRT process was implemented and then later evaluation and review of the outcomes of the process. The review results indicated that the Rapid response calls had a significant increase while a decrease in the number of code blue calls. The findings facilitated the creation of action plans with a focus on safety and education. Additionally, according to the findings of the survey, there should be supplies that lead to standardized box placed at the bedside of every RRT call. Consequently, staff and patient satisfaction was on the rise as outcomes improved (Critical Care Nurse, 1). The aim of the program is to advocate and initiate enteral nutrition for critically ill patients within 24 to 48 hours as means of improving outcomes (Critical Care Nurse, 1). Feeding into stomach normally leads to suboptimal enteral intakes due to the feedings being held for gastric residual volumes (GRV) or can also lead to patient intolerance due to ileus. The shared governance committee decided upon the use of an Electromagnetic Placement System (EMPS) to achieve safe enteral access beyond the pylorus. Postpyloric feeding is advantageous since it leads to greater enteral nutrition delivery to patients, as there are minimal interruptions of feeding (Critical Care Nurse, 1). Collaborative efforts also led to the establishment of a training program together with hands – on opportunities for bedside placement of the tube by the nurse. Furthermore, additional online support was availed on the

Addition to Pain Medication: Causes, Effects and Treatments

Addition to Pain Medication: Causes, Effects and Treatments Pain Medication Addictions Angelia Holland People are going to the doctor when they are nothing wrong with them to get a prescription for pain pills. People are getting more and more addicted to prescription pain pills. When doctors do not prescribe them a prescription because they suspect that are abusing the pills, then they will buy them for someone. These pills will not stop when they have an addiction sometime they abuse it so bad that they overdose because they mix pills together and do not know the outcome will be. However, pain pills misuse is a common thing now then it was in the past. No one decides to get addicted to prescription pain pills. Alienating family and friends, failing at work, and launching a small-time criminal career arent what anyone plans on when they swallow their first pain pill. One in five Americans report misusing a prescription drug at least once in their lifetime, but the overwhelming majority put the pills away with no lasting harm. So how does prescription painkiller abuse progress to full-blown opioid addiction? It typically starts with a visit to the doctor for a backache or to dull pain after surgery, an accident or a sports injury. It ends with addiction. Misuse of prescription painkillers is on the rise, and experts say increasingly, its killing us (Shamus, 2013). Healthcare providers have long wrestled with how best to treat patients who suffer from chronic pain, roughly 116 million in this country. No special training, skill, effort or techniques are required for pain management when using narcotic painkillers. You simply take a pill and soon afterward, the pain you were feeling is reduced or eliminated. The fact that these painkillers work well with little effort makes them the first choice for pain management for many people. Rather than exploring other ways of managing pain, which take effort and may not eliminate pain to the same extent as the painkillers, people reach for the pill bottle each time pain relief is required. The ease of use and effectiveness it brings may lead some to reach for the drugs more often than is safe or necessary. While it may not be the first reason that people take such painkillers, most notice that while they are under the influence of these drugs, they are distanced from their emotional pain. Painful emotions are a part of everyday life for all of us, but often we can manage these feelings on our own or with professional help, such as counseling. However, people in physical pain have often suffered emotional trauma and are more vulnerable to the attractions of a pill that just makes it all go away. Over time, people come to depend on their prescription painkillers to manage their negative emotions. Painkillers can be pleasurable. Opioids, in particular, have a side effect of euphoria. This is similar to the pleasure felt when you have been successful or after intense physical excitement, but it requires no such effort to attain. As people who are in pain have typically suffered an unpleasant experience that caused the pain, the pleasurable effects of these painkillers can seem like a delightful surprise. Seeking repeated experiences of pleasure through the addictive behavior or substance is one of the hallmarks of addiction. People with physical pain are often very tense. Because many painkillers, such as Demerol, induce physical relaxation, they can provide welcome relief from tension while under the influence. After a while, people can come to rely on painkillers that have this effect to provide relief from tension and the added pain that tension causes. Tolerance builds up quickly. Opioids can quickly cause tolerance to occur. As a result, people who regularly take these painkillers find that they need to take higher and higher dosages of the drug they are on in order to get the same effect. In addition to physical tolerance, people develop psychological tolerance as they become desensitized to the effects of the drug. Tolerance is one of the key signs that addiction is developing. Often, people who are becoming addicted to narcotic painkillers believe they need more of the drug because their pain is getting worse. But the worsening is often a result of the painkiller use itself. The ups and downs of a developing addiction because physical behaviors such as overuse of an injured part of the body, poor posture resulting from a lack of sensation when in positions that would otherwise be uncomfortable, and a lack of moderate exercise that would otherwise strengthen the weakened area (Hartney, 2011). Instead of correcting these bad habits, the person will often just take more painkillers, creating a vicious cycle of physical neglect being concealed by the effects of the drugs. As people become addicted to painkillers, they experience withdrawal when the drug wears off. Withdrawal is very unpleasant, and it often feels like an intensifying of the very symptoms the person was trying to escape through taking the painkillers. Pain, digestive problems and feelings of being generally unwell are common. As soon as the drug is taken, the unpleasant withdrawal symptoms disappear, and the person feels relieved of pain, relaxed, and free of tension and emotional distress. Over time, the person will choose to manage withdrawal symptoms through regularly taking more painkillers, sometimes without even realizing the withdrawal symptoms are caused by the drug itself (Hartney, 2011). The physical signs of addiction. Many times, painkiller addicts do not recognize the signs of their addiction until their behavior is pointed out to them. Painkillers can cause slurred speech and depression that they often attribute to other causes. Other physical symptoms of painkiller addiction include the inability to concentrate, lack of coordination and dizziness. Health care providers often recognize the symptoms because of declining blood pressure levels and slow, labored breathing. Narcotic painkillers also produce constipation. In addition to the obvious physical signs that result in unusual behavior, people who are addicted to painkillers begin to exhibit other behaviors inconsistent with their usual habits. Students often begin to find more reasons to stay home from school and start to receive falling grades. Lethargy and reduced energy levels are very common to painkiller addicts and are especially notable when they were previously considered active and enjoyed physical activities. Appearance becomes less important to addicts, and they may begin to have money troubles that lead them to ask for loans and get behind in their bills. As a painkiller addict withdraws from the drugs, the signs of addiction become more apparent. The National Institutes of Health reports that withdrawal from opioid painkillers brings on bone aches, chills, insomnia, diarrhea and vomiting. Involuntary leg movements, restlessness and muscle pain also may be present. People withdrawing from painkillers should be medically supervised during the first few days of treatment because the symptoms can be life threatening. Withdrawal from sedatives and tranquilizers can cause convulsions. Before taking pain medications, do your research Miotto of WebMD explains: â€Å"Weigh Your Risk Factors A history of addiction to prescription medicine or illicit drugs. Addiction to alcohol or tobacco. Family history of addiction. A history of mood disorders (such as depression or bipolar disorder), anxiety disorders (including PTSD), thought disorders (such as schizophrenia), and personality disorders (such as borderline personality disorder). Look at Other Options Physical therapy. Working with a psychologist to learn how to change your pain-related thoughts and behaviors. Alternative approaches such as acupuncture and tai chi. Those methods arent just for people who are at high risk for addiction. Theyre part of an overall pain management strategy that may include, but is not limited to, medications. Use the Medication for Its Proper Purpose If your doctor writes you a prescription that makes your pain more tolerable, and youre using it as directed, thats OK. But if youre using it for some other reason that your doctor doesnt know about, thats a red flag. For example, if you hate your job and youre taking the drug because you find it takes the edge off, thats a sign that you could develop a problem, says Karen Miotto, MD, an addiction psychiatrist at UCLA. Here are four warning signs that you may be misusing your prescription painkiller: Youre not taking the drug as prescribed. Youre taking the medicine for reasons other than why the doctor prescribed it. Your use of the drug has made you miss work or school, neglect your children, or suffer other harmful consequences. You havent been honest (with your doctor, loved ones, or yourself) about your use of the drug. Your doctor should work with you to limit addiction risk. She may ask you about how youre doing, give you a urine test to check for medication, and ask you to bring in all your medications so she can check how many are left and where the prescriptions came from. â€Å"If you feel like youre losing control over your pain medicine use, or if you have questions about whether youre becoming addicted to it, you may want to consult a doctor who specializes in pain medicine. He or she should listen to your concerns without judgment and take a reasoned approach. For instance, if she thinks you need to get off a certain drug, she might look into switching you to another drug with less potential for misuse. If your doctor isnt comfortable handling your situation, consider getting a second opinion from a psychiatrist or addiction specialist,† Miotto says. Pain-relieving drugs can lead to problems other than addiction. Keep opiates locked away so kids, teens, and others in your home cant take them. And be extra-cautious using other prescription and over-the-counter drugs along with opiates. Certain combinations could cause you to become unconscious, stop breathing, and even die (Miotto, 2012). Thousands of Americans rely on prescription painkillers for the relief of pain and discomfort from ailments such as headaches, menstrual cramps, surgery recovery or lingering pain from an injury. Unfortunately however, for many, this reliance on medication can easily and unknowingly turn into physical dependence. The scary fact is that the most commonly prescribed drugs including OxyContin, Vicodin, Methadone, Darvocet, Lortab, Lorcet and Percocet, while offering relief from pain, can also cause individuals bodies to start needing the drugs in order to feel normal, and the result is the new, even more challenging situation of chemical dependency Prescriptions to pain medication can be safe when taken according to the doctors instructions and are carefully monitored. However, it is important to recognize that they can also be very dangerous. Remember that dependency is a disease that can exhibit itself to even the most cautious individual. Therefore, anyone who is prescribed pain medications should take extra precautions to avoid the debilitating effects a dependency can have and watch for the warning signs (Bernstein, 2013) Celeste Vaughan states it correctly when she describes addiction, â€Å"When addiction takes control, Satan has a wide-open gate to enter and set up residence in your brain. He is the great justifier of all actions. He will provide you with excuses for the actions above to make you deny your addiction. The thoughts that you used to control now have a new pilot behind the wheel. And a sneaky one at that. If you do consider getting help, he will get inside your head and tell you all kinds of horrible things. Thinks like†¦No one will understand. Everyone will thing you’re weak. Friends will ever trust you again. Your husband will want a divorce. Your kids will be ashamed of you. And the worst one of all†¦If God truly loves you, he wouldn’t have let you get into this mess in the first place†¦Ã¢â‚¬ ¦.. You are on a journey — possibly the most difficult of your life. Don’t let anyone tell you that addiction is impossible to overcome. I’m p roof it’s completely possible. After all, with God, all things are possible.† The disease of addiction affects over 23 million Americans. It is a disease that has no cure, and that, as a society, we have just begun to understand. Help fight the stigma that an addict faces by learning all you can about this disease and its affects. The physical aspects of opioid dependency improve after detox. But psychological addiction, temptation, and craving can last for years, even a lifetime. The truth is, most people will relapse on their way to full recovery from prescription drug addiction (Johnson, 2012). Staying on the path to health takes patience, loving relationships, and emotional resilience. People in drug abuse recovery need all the help they can get. Fortunately, tools and resources are available to help someone stay straight, and to pick them up if they stumble. â€Å"Consider it pure joy, my brothers and sisters, whenever you face trials of many kinds, because you know that the testing of your faith produces perseverance. Let perseverance finish its work so that you may be mature and complete, not lacking anything.† (James 1:2-4 NIV) References Clifford M.D., of The Waismann Institute. 10/6/2003. Retrieved from http://www.medicinenet.com/script/main/art.asp?articlekey=24572 Hartney, Elizabeth PhD. February 20, 2011. Retrieved from http://addictions.about.com/od/substancedependence/tp/painkillers.htm Johnson, Kimball, MD. August 02, 2012. Maintaining Hope and Health during Drug Abuse Recovery. Retrieved from http://www.webmd.com/mental-health/drug-abuse-recovery-maintaining-hope-and-health?page=2 Miotto, Karen, MD, professor of psychiatry and bio behavioral sciences, UCLA.. 2012. Pain Medication: Are You Addicted? What to know about becoming addicted to pain medications. Retrieved from http://www.webmd.com/pain-management/features/pain-medication-addiction?page=2 Shamus, Kristen Jordan. October 20, 2013. Pain pills can be prescriptions for addiction, death. Retrieved from http://www.usatoday.com/story/news/nation/2013/10/20/painkiller-overdoses-addiction/3107879/ Vaughan, Celeste. November 5, 2012. Biblical Christian help for drug addiction. Retrieved from http://drug.addictionblog.org/biblical-christian-help-for-drug-addiction/

Essay --

Willie Breslau Professor Pollak COML 1109 11/27/13 â€Å"Reluctance† by Robert Frost An extended metaphor of a road, that represents the mans life and journey he has taken, runs throughout Robert Frost’s poem â€Å"Reluctance†. The title and the last line help to break through the metaphor and understand the meaning behind it, as Frost deliberates humans’ hesitation to accept change and the inevitability of a natural end, whether of â€Å"a love or a season†. â€Å"Reluctance,† along with several other Frost poems, focuses on the change of seasons and how the narrator reacts to that change. However, while each narrator of â€Å"Reluctance†, â€Å"Spring Pools†, and â€Å"Nothing Gold can Stay† display different emotions about the seasonal changes they witness, they all display humans hesitation to except change and to hold onto what they have in the present. The sketch that I drew for this poem has a man who looks withered from travel with a long beard and wrinkled skin walking alone on a â€Å"highway†. Behind the narrator, I drew a small globe to represent that he is now returning from his travels around the world and in front of him a small town labeled home. Around the man stands on the highway are trees that have lost most of their leaves and leaves that are being blown on the snow covered ground. Other plants are drawn with fleeting life, as winter seems to be coming if not already here. â€Å"Reluctance’ consists of five stanzas each having six lines. The meter of the poem is tricky. In Frost terms, this poem could be considered to be in loose iambic trimeter, but would be more aptly described as trimeter. One interesting feature of this poems meter is that the last line of each stanza switches from trimeter to dimeter. Each stanza consists of the rhyme sc... ... In all three poems, change is represented as a transition between seasons with the narrator being enthralled by the present and not wanting time to change what they have. In â€Å"Reluctance† the seasons are more than actual seasons as the display a turning point in the narrators where he must decide to embrace change or follow his heart. In â€Å"Spring Pools† and â€Å"Nothing Gold Can Stay† the narrators both emphasize the short-lived beauty of nature because of the change in seasons and want so desperately the delay that change. However, both narrators almost reluctantly come to the conclusion that change can bring more beauty but are worried to lose what they have in the present. Frost’s mastery of poetry, nature, and human behavior are beautifully intertwined in these poems to create powerful messages that will continue to be relevant as mankind struggles to accept change.

Reardon v. U.S. Essay

Lien on real property created by CERCLA when Environmental Protection Agency (EPA) determines that property owners may be liable for cleanup costs amounts to deprivation of a significant property interest within meaning of the due process clause. Comprehensive Environmental Response, Compensation, and Liability Act of 1980,  § 107(l ), as amended, 42 U.S.C.A.  § 9607(l ); U.S.C.A. Const.Amend. 5. Absence of notice and hearing may be justified by exigent circumstances. U.S.C.A. Const.Amend. 5. 92k251.5 k. Procedural Due Process in General. Most Cited Cases Constitution allows the process due to be tailored to fit realities of the situation. U.S.C.A. Const.Amend. 5. *1510 Lynn Wright, with whom Robin F. Price and Edwards and Angell, New York City, were on supplemental brief, for plaintiffs, appellants. George W. Van Cleve, Deputy Asst. Atty. Gen., with whom Barry Hartman, Asst. Atty. Gen., Washington, D.C., Wayne A. Budd, U.S. Atty., George B. Henderson, II, Asst. U.S. Atty., Boston, Mass., Stephen L. Samuels, Steve C. Gold, Jacques B. Gelin, Attys., Dept. of Justice, Charles Openschowski, Office of Gen. Counsel, E.P.A. and Luis Rodriguez, Asst. Regional Counsel, E.P.A., Washington, D.C., were on supplemental brief, for defendants, appellees. OPINION EN BANC TORRUELLA, Circuit Judge. After removing hazardous substances from property belonging to the Reardons, EPA filed a notice of lien on the property for the amount spent. See 42 U.S.C.  § 9607(l ). The Reardons sued to have the notice of lien removed, arguing that they were not liable for the cleanup costs, that the lien was  overextensive in that it covered parcels not involved in the clean-up, and that the filing of the lien notice without a hearing deprived them of property without due process. The district court, in Reardon v. United States, 731 F.Supp. 558 (D.Mass.1990), decided that it did not have jurisdiction to hear the Reardons’ two statutory claims. It ruled that although jurisdiction existed to hear the constitutional claim, the filing of a lien did not amount to a taking of a significant property interest protected by the due process clause. It therefore denied the Reardons’ motion for a preliminary injunction, and dismissed their complaint. The Reardons appealed and a panel of this court ruled in their favor on statutory grounds. Reardon v. United States, 922 F.2d 28 (1st Cir.1990) (withdrawn). We now consider the appeal en banc. After closely considering applicable law, including most notably the recent case of Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), we conclude that the district court correctly decided that it did not have jurisdiction to consider the Reardons’ statutory claims, but we find that the CERCLA lien provisions do violate the fifth amendment due process clause. I. BACKGROUND A. Facts. In 1979, Paul and John Reardon purchased a 16-acre parcel in Norwood, Massachusetts, adjacent to an electric equipment manufacturing plant site *1511 known as the â€Å"Grant Gear† site, and named it â€Å"Kerry Place.† In 1983, the Massachusetts Department of Environmental Quality Engineering, responding to a report of a nearby resident, tested soil samples from both properties and discovered extremely high levels of polychlorinated biphenyls (â€Å"PCBs†) on the Grant Gear site and on Kerry Place where it bordered Grant Gear. EPA then investigated the site. Finding the same high levels of PCBs, it authorized an immediate clean-up of the contaminated areas. Between June 25 and August 1, 1983, EPA removed 518 tons of contaminated soil from the two properties. It then notified the Reardons that it had removed all soil with concentrations of PCBs known to be above the safe limit, but informed them that additional areas of contamination might exist, in whi ch case EPA might undertake additional clean-up work. In 1984, the Reardons subdivided Kerry Place into a number of parcels; they sold five of those parcels and retained ownership of the others. In October 1985, EPA notified the Reardons that, as current owners of Kerry Place, they might be liable under  §Ã‚ § 106  and 107 of the Comprehensive Environmental Response, Compensation, and Liability Act (â€Å"CERCLA†), 42 U.S.C.  §Ã‚ § 9606 & 9607, along with ten other present and prior owners of the properties, for the clean-up costs. In August 1987, EPA again investigated the properties to assess the feasibility of a long-term remedy for any remaining contamination. New testing showed that soil in several areas on Kerry Place was still contaminated with PCBs. In April 1988, EPA informed the Reardons of these results. The Reardons told EPA that they intended to clean up their property themselves. EPA advised the Reardons to coordinate any offsite disposal plans with EPA and to obtain EPA’s approval of a treatment or disposal facility. In January 1989, the Reardons informed EPA that they had completed their own clean-up of Kerry Place, without having attempted coordination with or sought the approval of EPA. On March 23, 1989, EPA filed a notice of lien with the Norfolk County Registry of Deeds pursuant to  § 107(l ) of CERCLA, 42 U.S.C.  § 9607(l ), on all of the Kerry Place parcels still owned by the Reardons. The lien was for an unspecified amount, as it secured payment of â€Å"all costs and damages covered by† 42 U.S.C.  § 9607(l ) for which the Reardons were liable under  § 107(a) of CERCLA, 42 U.S.C.  § 9607(a). Five days later, EPA notified the Reardons that it had filed the notice of lien. On July 12, 1989, EPA informed the Reardons that they could settle EPA’s claims against them for $336,709, but noted that this amount did not limit the Reardons’ potential liability. On September 29, 1989, EPA selected a long-term remedy for the Kerry Place and Grant Gear sites estimated to cost $16,100,000. B. Procedural History. The Reardons filed a complaint and a motion for preliminary injunction in the United States District Court for the District of Massachusetts. They argued that they were entitled to have the notice of lien removed for three reasons. First, the Reardons maintained that they qualified as â€Å"innocent landowners† under  § 107(b) of CERCLA, 42 U.S.C.  § 9607(b), and therefore were not liable for any clean-up costs. Second, 42 U.S.C.  § 9607(l ) provides for a lien on only that property â€Å"subject to or affected by a removal or remedial action,† 42 U.S.C.  § 9607(l )(1)(B); the Reardons claim that since some of their Kerry Place parcels were not â€Å"subject to or affected by† the clean-up, EPA erred in filing a notice of lien covering all of those parcels. Third, they asserted that EPA’s imposition of the lien without a hearing violated the due process clause of  the fifth amendment to the United States Constitution. The district court held that  § 113(h) of CERCLA, 42 U.S.C.  § 9613(h), divested it of jurisdiction to hear the Reardons’ â€Å"innocent landowner† and â€Å"overbroad lien† claims. It found that the same section also purported to divest it of jurisdiction to hear the due process claim, but held that Congress was without power to place such a limitation on its jurisdiction. Turning to the merits of the due process claim, the *1512 district court held that the lien imposed by  § 107(l ) did not amount to a taking of a â€Å"significant property interest† protected by the due process clause. The court therefore denied the motion for a preliminary injunction and dismissed the complaint. The Reardons appealed, and a panel of this court found in their favor. The panel opinion construed  § 9613(h) so as to permit judicial review of the statutory challenges to the lien, and did not reach the due process issue. In response to EPA’s petition for rehearing, however, a majority of the court voted to grant a rehearing en banc. Although the court en banc finds for the plaintiffs, as did the panel, we do so on constitutional rather than statutory grounds. II. JURISDICTION [1] We turn first to the question of jurisdiction. The district court, as we have noted, held that 42 U.S.C.  § 9613(h) purported to divest it of jurisdiction over all three of the Reardons’ claims. We agree that  § 9613(h) bars review of the â€Å"innocent landowner† and â€Å"overbroad lien† claims, prior to the commencement of an enforcement or recovery action, but we conclude that this section does not bar review of the due process claim. Section 9613(h), entitled â€Å"Timing of review,† explicitly limits the jurisdiction of the federal courts to hear certain cases arising under CERCLA. The section states, in part: No federal court shall have jurisdiction under Federal law †¦ to review any challenges to removal or remedial action selected under section 9604 of this title, or to review any order issued under section 9606(a) of this title, in any action except one of the following: [listing 5 enumerated types of actions] 42 U.S.C.  § 9613(h). The five exceptions to the jurisdictional bar are all actions filed by the government or by a private citizen seeking to enforce or recover costs for the enforcement of CERCLA; for this reason, the district court described  § 9613(h) as barring â€Å"judicial review of EPA actions prior to the time that the EPA or a third  party undertakes a legal action to enforce an order or to seek recovery of costs for the cleanup of a hazardous waste site.† Reardon v. United States, 731 F.Supp. at 564 n. 8. As a convenient shorthand, we will say that  § 9613(h) bars â€Å"pre-enforcement review† of certain claims. The district court framed the question of jurisdiction as whether the filing of a lien constituted a â€Å"removal or remedial action selected under section 9604 of this title.† As the district court noted, the terms â€Å"removal† and â€Å"remedial action† are defined terms under the CERCLA statute. 42 U.S.C.  §Ã‚ § 9601(23), (24). Another C ERCLA provision says that these terms â€Å"include enforcement activities related thereto.† 42 U.S.C.  § 9601(25) (emphasis added). The court found that placing a lien on property from which hazardous substances had been removed was a type of enforcement activity. It therefore concluded that any challenge the Reardons could make, whether statutory or constitutional, was a â€Å"challenge[ ] to [a] removal or remedial action† over which Congress intended it not to have jurisdiction unless and until EPA brought an enforcement action. Reardon v. United States, 731 F.Supp. at 569. A. Jurisdiction over the â€Å"innocent landowner† and â€Å"overbroad lien† claims. We agree with the district court that filing a lien notice is a type of â€Å"enforcement activity† related to a removal or remedial action. And we agree that  § 9613(h) bars the federal courts from hearing pre-enforcement challenges to the merits of any particular lien–challenges, for example, to the liability which a lien secures, or to the conformity of that lien to the CERCLA lien provisions. Several considerations l ead to these conclusions. First, we think that the language of the statute, read for its ordinary meaning, supports such an interpretation. Central to the entire CERCLA scheme is a provision that makes certain parties liable for the cost of removal and remedial actions. See 42 U.S.C.  § 9607(a). When the government files a lien on property to secure payment of that liability, it can reasonably be described as seeking to enforce the liability *1513 provision. Thus, the activity of filing liens is, in ordinary language, an â€Å"enforcement activity.† Second, we believe that allowing challenges to the merits of particular liens would defeat some of the purposes of barring pre-enforcement review under  § 9613(h). Congress was no doubt concerned, first and foremost, that clean-up of substances that endanger public health would be delayed if EPA were forced to litigate each detail of its removal  and remedial plans before implementing them. Thus, the Senate Judiciary Committee Report stated that  § 9613(h) barred pre-enforcement review because such review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre-enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlement and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). As long as the remedy upon review of a lien was limited to the invalidation or modification of the lien, of course, such review would not directly delay clean-up of hazardous substances. However, we do not believe that avoiding delay was the only purpose of postponing review. As the Fifth Circuit stated in a similar case: Although review in the case at hand would not delay actual cleanup of hazardous wastes, it would force the EPA–against the wishes of Congress–to engage in â€Å"piecemeal† litigation and use its resources to protect its rights to recover from any [potentially responsible party] filing such a[n] action. . . . . . Moreover, the crazy-quilt litigation that could result from allowing [potentially responsible parties] to file declaratory judgment actions prior to the initiation of government cost recovery actions could force the EPA to confront inconsistent results. Voluntary Purchasing Groups, Inc. v. Reilly, 889 F.2d 1380, 1390 (5th Cir.1989). The same practical considerations weigh against allowing pre-enforcement review in this case. And we add to these reasons one more: information needed to decide legal challenges to liens may not be available at the time such challenges are made. To decide, for example, the Reardons’ claim that they are innocent landowners, a court must determine whether the contamination pre-dated their ownership; whether they had any knowledge or reason to know of the contamination; whether they had exercised due care with respect to the hazardous substances; and whether they took precautions to prevent releases by foreseeable acts of third parties. See 42 U.S.C.  § 9607(a), (b)(3), EPA Supplemental Brief, at 16-17 (stressing complexity of resolving innocent landowner claim). Notices of liens are likely to be filed early in the history of a response action–shortly after EPA has begun to spend money on waste removal and the  landowner has been notified of potential responsibility. See 42 U.S.C.  § 9607(l ) (providing for creation and filing of liens). At that point, EPA is likely not yet to know the full extent of the contamination, let alone when that contamination occurred, or whether it is likely that the owner exercised due care or took reasonable precautions. One purpose of  § 9613(h), we believe, is to delay review until enough is known to decide these issues. Third, legislative history supports the view that  § 9613(h) is intended to bar challenges to liability, such as the Reardons seek to make by attacking the lien filing, as well as challenges to the remedy EPA has chosen. During floor debate on this section, Senator Thurmond, Chairman of the Judiciary Committee, which drafted the section, explained: Citizens, including potentially responsible parties, cannot seek review of the response action or their potential liability for a response action –other than in a suit for contribution–unless the suit falls within one of the categories in this section†¦. 132 Cong.Rec. S14929 (daily ed. Oct. 3, 1986) (emphasis added). Senator Stafford, *1514 Chairman of the Conference Committee, stated: â€Å"When the essence of a lawsuit involves the contesting [of] the liability of the plaintiff for cleanup costs, the courts are to apply the provisions of section 113(h), delaying such challenges until the Government has filed a suit.† 132 Cong.Rec. S14898 (daily ed. Oct. 3, 1986) (emphasis added). It is certainly possible that Congress inadvertently rather than purposefully included lien challenges in the judicial review bar. Congress amended the scope of â€Å"removal† and â€Å"remedial† actions to include â€Å"enforcement activities related thereto† primarily to ensure that EPA could â€Å"recover costs for enforcement actions taken against responsible parties.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 66-67, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2848-49; see H.R.Conf.Rep. No. 962, 99th Cong., 2d Sess. 185, reprinted in 1986 U.S.Code Cong. & Admin.News 3276, 3278 (â€Å"This amendment clarifies and confirms that [enforcement activity] costs are recoverable from responsible parties.†). Perhaps Congress did not realize that other provisions referring to removal and remedial actions–such as the judicial review bar–would also be affected. But even if this were so, we do not see how our conclusion is altered. First, as outlined above, reading the statute to bar review of pre- enforcement challenges to liens is consistent with the language and the purpose of the judicial bar. Second, and more importantly,  Congress amended a definitional section, thus changing the meaning of â€Å"removal† and â€Å"remedial† wherever they appear in CERCLA. We cannot give the definition inconsistent readings within the statute. As the above-quoted legislative history makes clear, the 1986 amendment was certainly intended to allow the government to collect attorney’s fees in cost recovery actions. See United States v. Ottati & Goss, 694 F.Supp. 977, 997 (D.N.H.1988) (allowing attorney’s fees to United States under  § 9607(a)(4)(A)), aff’d in part, vacated in part, 900 F.2d 429 (1st Cir.1990). If liens to ensure the government’s complete recovery of its remedial costs are not â€Å"enforcement activities† related to the removal or remedial action–the view suggested by the dissent–then we do not see how a suit to recover the government’s clean up costs is an â€Å"enforcement activit[y]† either. And if â€Å"enforcement activities† in  § 9601(25) is interpreted to exclude the expenses of cost recovery actions, this would have the effect of denying the government significant amounts of attorney’s fees– which was certainly not the intent of Congress. We therefore conclude, as did the district court, that  § 9613(h) precludes judicial review of the imposition of a lien until EPA commences an enforcement action. [2] B. Jurisdiction over the due process claim. Unlike the district court, however, we do not believe that  § 9613(h) precludes federal court jurisdiction over the Reardons’ due process claim. First, such a challenge does not fit into the literal language of  § 9613(h). That section refers to â€Å"challenges to removal or remedial action selected under section 9604 of this title.† Under our reading, it divests federal courts of jurisdiction over challenges to EPA’s administration of the statute–claims that EPA did not â€Å"select[ ] † the proper â€Å"removal or remedial action,† in light of the standards and constraints established by the CERCLA statutes. The Reardons’ due process claim is not a challenge to the way in which EPA is administering the statute; it does not concern the merits of any particular removal or remedial action. Rather, it is a challenge to the CERCLA statute itself–to a statutory scheme under which the government is authorized to file lien notices without any hearing on the validity of the lien. Second, we read  § 9613(h) in light of the Supreme Court’s oft-repeated pronouncement that â€Å"where Congress intends to preclude judicial review of constitutional  claims its intent to do so must be clear.† Webster v. Doe, 486 U.S. 592, 603, 108 S.Ct. 2047, 2053-54, 100 L.Ed.2d 632 (1988); see Weinberger v. Salfi, 422 U.S. 749, 95 S.Ct. 2457, 45 L.Ed.2d 522 (1975); *1515 Johnson v. Robison, 415 U.S. 361, 94 S.Ct. 1160, 39 L.Ed.2d 389 (1974). [FN1] We do not believe that the statute expresses a clear congressional intent to preclude the type of constitutional claim the Reardons are making–a challenge to several statutory provisions which form part of CERCLA. However, it is important to make clear that we are not holding that all constitutional challenges involving CERCLA fall outside the scope of  § 9613(h). A constitutional challenge to EPA administration of the statute may be subject to  § 9613(h)’s strictures. Such a claim may well be a â€Å"challenge[ ] to removal or remedial action selected under section 9604 of this title,† and may thus fall within  § 9613(h)’s bar. We find only that a constitutional challenge to the CERCLA statute is not covered by  § 9613(h). FN1. Of course,  § 9613(h) is styled as a provision that merely delays review, rather than precludes it–indeed, it is titled â€Å"Timing of review.† However, the only available review of the lien notice is in an enforcement action brought by EPA; and the judgment in that enforcement action will render moot the Reardons’ due-process-based request for injunctive relief against the filing of the lien, since it will decide whether or not the Reardons are liable under CERCLA. Hence, the effect of  § 9613(h) is to preclude review altogether. Third, extending jurisdiction to the Reardons’ due process claim does not necessarily run counter to the purposes underlying  § 9613(h). For example, resolution of the due process issue does not require any information that is not likely to be available until clean-up of a site is finished. Because it is a purely legal issue, its resolution in a pre-enforcement proceeding does not have the potential to force EPA to confront inconsistent results (as would a finding, for example, that a particular spill was caused by an act of God). Of course, if we decide that filing a notice of a CERCLA lien without any pre- enforcement review does violate due process, EPA’s collection efforts will no doubt be hampered. However, we do not lightly assume that Congress intended to ease EPA’s path even at the expense of  violating the Constitution. Fourth, although the two courts that have considered this issue have reached a different conclusion, see Barmet Aluminum Corp. v. Re illy, 927 F.2d 289, 293 (6th Cir.1991); South Macomb Disposal Authority v. U.S.E.P.A., 681 F.Supp. 1244, 1249-51 (E.D.Mich.1988), we are unpersuaded by the reasoning of those cases. Our disagreement commences with the phrasing of the issue to be decided. Both courts frame the question as whether  § 9613(h) â€Å"prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute.† South Macomb, 681 F.Supp. at 1249-50; see Barmet, 927 F.2d at 292. We think that this question fails to make the distinction we have noted above, see pp. 1514-1515, supra, between two types of constitutional challenges–challenges to EPA’s administration of CERCLA, and challenges to CERCLA itself. Once we recognize this distinction, the reasoning of these two courts becomes less convincing. First, says the South Macomb court, Reading the language of  § 9613(h) for its everyday meaning supports the notion that this subsection prohibits constitutional as well as statutory challenges until the time pr[e]scribed by the statute. The provision explicitly states that federal courts shall not have jurisdiction to review â€Å"any challenge† except for those enumerated. South Macomb, 681 F.Supp. at 1249- 50. But, the statute does not bar â€Å"any challenge,† without qualification; rather, it delays federal court review of â€Å"any challenges to removal or remedial action selected under section 9604 of this title.† 42 U.S.C.  § 9613(h). Because a due process challenge to the CERCLA lien provisions is not, we believe, a challenge to â€Å"removal or remedial action selected under section 9604 of this title,† we do not find that the â€Å"everyday meaning† of  § 9613(h) divests the federal courts of jurisdiction to hear such a challenge. Both the Barmet and South Macomb courts contend that legislative history–House and Senate Reports, and House Judiciary Committee Hearings– suggests that Congress intended  § 9613(h) to bar all pre-enforcement challenges, including all *1516 constitutional challenges. Upon examination, we find these materials unconvincing as well. The Senate Report states, in part: As several courts have noted, the scheme and purposes of CERCLA would be disrupted by affording review of orders or response actions prior to commencement of a government enforcement or cost recovery action. See, e.g., Lone Pine Steering Committee v. EPA, [600 F.Supp. 1487 (D.N.J.1985) ]. These cases  correctly interpret CERCLA with regard to the unavailability of pre-enforcement review. This amendment [ § 9613(h) ] is to expressly recognize that pre-enforcement review would be a significant obstacle to the implementation of response actions and the use of administrative orders. Pre- enforcement review would lead to considerable delay in providing cleanups, would increase response costs, and would discourage settlements and voluntary cleanups. S.Rep. No. 11, 99th Cong., 1st Sess. 58 (1985). We see nothing in this discussion which would indicate an intent to divest federal courts of jurisdiction to consider a claim that the provisions of CERCLA itself authorize deprivations of property without due process of law. On the contrary, the reference to â€Å"review of orders or response actions† suggests that the writers of the Senate Report focused their concern on the problems that would arise if courts reviewed the merits of particular EPA actions. Both Barmet and South Macomb attach great weight to the Senate Report’s citation â€Å"with approval† of Lone Pine, a case decided before  § 9613(h) was enacted, which they say held that CERCLA did not allow pre- enforcement review even of constitutional challenges. We think there are good reasons to discount this citation. For one thing, the 13-page opinion in Lone Pine contains no discussion of the question whether constitutional challenges to the statute as well as challenges to administrative action are barred; one can only infer that the Lone Pine court held this view from the facts that (1) the plaintiff’s complaint had one constitutional count alongside six statutory counts, and (2) the court dismissed the entire complaint. In fact, Lone Pine cites Aminoil, Inc. v. EPA, 599 F.Supp. 69, 72 (C.D.Cal.1984), the leading case holding that CERCLA did not bar jurisdiction to review constitutional challenges to the statute; and it does so, not to indicate any disagreement with that holding, but simply to agree with its holding that CERCLA does bar pre-enforcement review of administrative orders. See Lone Pine, 600 F.Supp. at 1497. For another thing, the Senate Report does not cite Lone Pine for the proposition that federal courts have no jurisdiction to hear constitutional challenges; rather, it cites it solely as an example of a group of cases, sub silentio holding that review â€Å"of orders or response actions† would disrupt the purposes of CERCLA. We do not see why this should indicate agreement with Lone Pine’s purported holding regarding constitutional challenges,  particularly since cases such as Aminoil would seem to fit just as easily into the group of cases described in the Report. We do not find the House Report any more convincing. The pertinent passage in that Report, according to Barmet and South Macomb, is a statement that â€Å"there is no right of judicial review of the Administrator’s selection and implementation of response actions until after the response action[s] have been completed†¦.† H.R.Rep. No. 253(I), 99th Cong., 2d Sess. 81, reprinted in 1986 U.S.Code Cong. & Admin.News 2835, 2863. See Barmet, 927 F.2d at 293 (quoting this passage); South Macomb, 681 F.Supp. at 1250 (same). This statement says nothing about judicial review of the CERCLA statute itself. South Macomb also cites testimony of EPA and Justice Department officials during hearings on the bill that contained  § 9613(h). In response to a query from Representative Glickman as to whether EPA and the Justice Department â€Å"might accept some form of accelerated [pre-enforcement] review,† Mr. Habicht, the Assistant Attorney General for Land and Natural Resources, replied: Mr. Chairman, briefly, this issue has been litigated under the 1980 statute *1517 quite extensively, and there have been a number of decisions over the last several months that address the fundamental questions of the constitutionality of the procedures set forth in that law. Virtually across the board now the courts are finding that the scheme is constitutional as currently constituted. Superfund Reauthorization: Judicial and Legal Issues, Hearings before the Subcomm. on Admin. Law and Governmental Relations, H. of Rep. Judiciary Comm., 99th Cong., 1st Sess. at 226 (July 17, 1985); see South Macomb, 681 F.Supp. at 1250 (quoting this passage). The South Macomb court comments: â€Å"Our reading of this exchange is that the EPA and the Department of Justice took the position that because the courts had already upheld the constitutionality of CERCLA, constitutional challenges could also await EPA enforcement actions.† Id. We do not find this passage quite so clear. It would appear to be an expression of hope by EPA and the Department of Justice rather than a statement of congressional intent, particularly in light of the fact that Congress passed a provision,  § 9613(h), that by its language does not bar constitutional challenges to the CERCLA statute. Finally, the Supreme Court recently examined a statute with a judicial review provision not unlike the CERCLA section analyzed here. At issue in McNary v. Haitian Refugee Center, Inc., 498 U.S. 479, 111 S.Ct. 888, 112  L.Ed.2d 1005 (1991), was a provision of the Immigration and Nationality Act barring judicial review of a denial of â€Å"Special Agriculture Worker† (â€Å"SAW†) status except in the context of a deportation order. The statute states: â€Å"There shall be no administrative or judicial review of a determination respecting an application for adjustment of status under this section except in accordance with this subsection.† 8 U.S.C.  § 1160(e) (as amended by the Immigration Reform and Control Act of 1986). The Court held that this bar did not preclude review of â€Å"general collateral challenges to unconstitutional practices and policies used by the agency in processing applications.† McNary, 111 S.Ct. at 896. Rather, it only barred review of individual denials of SAW status. Id. The statute in McNary resembles the CERCLA provision at issue here in two respects. First, as here, judicial review of an administrative event is withheld until the agency instigates a second, independent proceeding. More significantly, the immigration statute is phrased so as to bar review of the agency’s determination of SAW status in an individual action–an event comparable to EPA’s selection of a removal or remedial action, which is the focus of the CERCLA bar. Neither statute mentions the availability of review of a constitutional challenge to the statute itself (as here) or to the agency’s execution of the statute (as in McNary ). Insofar as the Immigration and Nationality Act compares to CERCLA, we think that the holding in McNary supports our conclusion here. See also Johnson v. Robinson, 415 U.S. 361, 367, 94 S.Ct. 1160, 1165-66, 39 L.Ed.2d 389 (1974) (holding that similar jurisdictional bar precluded review only of administration of statute, not of challenge to statute itself); cf. Weinberger v. Salfi, 422 U.S. 749, 762, 95 S.Ct. 2457, 2465, 45 L.Ed.2d 522 (1975) (holding that more expansive language barred all challenges related to statute). Thus, we conclude that we have jurisdiction to consider the Reardons’ due process claim: that the CERCLA statutory scheme under which liens may be imposed on property without opportunity for a hearing violates the fifth amendment due process clause. III. THE DUE PROCESS CLAIM [4] The Supreme Court has established a two-part analysis of due process challenges to statutes which, like this one, involve property rather than liberty interests. One must first ask whether the statute authorizes the taking of a â€Å"significant property interest† protected by the fifth  amendment. E.g., Fuentes v. Shevin, 407 U.S. 67, 86, 92 S.Ct. 1983, 1997, 32 L.Ed.2d 556 (1972). If there is no significant property interest involved, the inquiry is at an end. If there is, one proceeds to examine what process is due in the particular circumstances. *1518 E.g., id.; Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18 (1976). We shall address each issue in turn. A. The Deprivation. The district court, relying primarily on Spielman- Fond, Inc. v. Hanson’s, Inc., 379 F.Supp. 997 (D.Ariz.1973) (three judge panel), aff’d mem., 417 U.S. 901, 94 S.Ct. 2596, 41 L.Ed.2d 208 (1974), found that the filing of a federal lien under 42 U.S.C.  § 96 07(l ) did not amount to a deprivation of a significant property interest; thus, the court did not reach the second step of the analysis. However, a Supreme Court case decided after the district court had issued its decision (indeed, after oral argument at the en banc rehearing of this appeal) has clarified the law in this area considerably, and has precluded continued reliance on the Court’s summary affirmance in Spielman-Fond. In Connecticut v. Doehr, 501 U.S. 1, 111 S.Ct. 2105, 115 L.Ed.2d 1 (1991), a unanimous Court held that a Connecticut attachment statute violated the due process clause. The Court held that the attachment lien on plaintiff Doehr’s real property deprived him of a significant property interest within the meaning of the due process clause. The Court stated: For a property owner like Doehr, attachment ordinarily clouds title; impairs the ability to sell or otherwise alienate the property; taints any credit rating; reduces the chance of obtaining a home equity loan or additional mortgage; and can even place an existing mortgage in technical default where there is an insecurity clause. Doehr, 501 U.S. at —-, 111 S.Ct. at 2113. It concluded that â€Å"even the temporary or partial impairments to property rights that attachments, liens, and similar encumbrances entail are sufficient to merit due process protection.† Id. (emphasis added). And, in a footnote, it disposed of its summary affirmance in Spielman-Fond by noting that â€Å"[a] summary disposition does not enjoy the full precedential value of a case argued on the merits and disposed of by a written opinion.† Id. at —- n. 4, 111 S.Ct. at 2113 n. 4 (citing Edelman v. Jordan, 415 U.S. 651, 671, 94 S.Ct. 1347, 1359-60, 39 L.Ed.2d 662 (1974)). See also id. at —-, 111 S.Ct. at 2113 (Rehnquist, C.J., concurring) (Spielman-Fond should not be read to mean that the imposition of a lien is not a deprivation of a significant interest in property). Whether the response costs were incurred consistently with the national contingency plan is an issue which may be highly factual, but it is usually a matter of the amount, and not the existence, of liability. More likely to be â€Å"highly factual† is the determination whether certain of the owner’s parcels of land are â€Å"subject to or affected by† EPA’s response action. Similarly, on the issue of the landowner’s liability, EPA admits in its brief that the â€Å"concepts of due care, foreseeability, objective and subjective knowledge, some of which are unique in CERCLA to the innocent landowner defense, are extremely fact-intensive.† EPA Supplementary Brief at 16-17. Second, we must consider what procedural safeguards, if any, CERCLA provides against erroneous filing of a lien. a. The right to a judicial hearing. CERCLA provides no such safeguards. It provides for no pre-deprivation proceedings at all–not even the ex parte â€Å"probable cause† hearing judged insufficient in Doehr. See Doehr at —-, 111 S.Ct. at 2108 (describing Connecticut attachment procedure). Nor does CERCLA provide for an immediate post-deprivation hearing. [FN2] The first hearing the property owner is likely to get is at the enforcement proceeding, or cost recovery action, brought by EPA. This action may be brought several years after the notice of lien is filed; it is limited only by a rather complicated statute of  limitations, see 42 U.S.C.  § 9613(g)(2), which gives EPA three years after a removal action is completed or six years after a remedial action is commenced to bring such a suit. The running of the statute of limitations is entirely within EPA’s control. Since the government may take its own sweet time before suing, and since the removal or remedial action may itself take years to complete, the lien may be in place for a considerable time without an opportunity for a hearing. FN2. The Connecticut statute at issue in Doehr provided â€Å"expeditious† post-attachment review, see 501 U.S. at —-, 111 S.Ct. at 2115, but the Court nonetheless found the statute constitutionally deficient. Even under Doehr, though, post-attachment process is not always inadequate. Doehr notes the factors leading to the Court’s  approval, in Mitchell v. W.T. Grant Co., 416 U.S. 600, 94 S.Ct. 1895 (1974), of a sequestration statute with no pre-deprivation review: â€Å"the plaintiff had a vendor’s lien to protect, the risk of error was minimal because the likelihood of recovery involved uncomplicated matters that lent themselves to documentary proof, and plaintiff was required to put up a bond.† Doehr, 501 U.S. at —-, 111 S.Ct. at 2114. â€Å"[M]ere postponement of judicial enquiry is not a denial of due process if the opportunity given for ultimate judicial determination of liability is adequate.† *1520 Phillips v. Commissioner, 283 U.S. 589, 596, 51 S.Ct. 608, 611, 75 L.Ed. 1289 (1931). But the CERCLA statute of limitations on liens throws the â€Å"ultimate judicial determination† so far into the future as to render it inadequate. Indeed, in this respect the CERCLA scheme resembles the replevin statutes in Fuentes v. Shevin, where the Court held that the debtor may not be â€Å"left in limbo to await a hearing that might or might not ‘eventually’ occur.† Mitchell v. W.T. Grant Co., 416 U.S. at 618, 94 S.Ct. at 1905 (discussing Fuentes v. Shevin ). b. Posting of a Bond. The Court has recognized that requiring the filing party to post a bond may provide the property owner important protection against wrongful filing; in Doehr, four members of the Court suggested that due process always requires a plaintiff’s bond in the context of an attachment. See Doehr, 501 U.S. at  Ã¢â‚¬â€-, 111 S.Ct. at 2116 (plurality). CERCLA does not require EPA to post a bond when filing the notice of federal lien. c. Action for damages. In Doehr, the State of Connecticut argued that the availability of a double damages remedy for suits that are commenced without probable cause was an important protection against misuse of the attachment provisions; however, four members of the Court did not find the availability of such a suit to be an adequate procedural safeguard. Four members of the court explained in detail why an action for damages would never prove adequate: The necessity for at least a prompt postattachment hearing is self-evident because the right to be compensated at the end of the case, if the plaintiff loses, for all provable injuries caused by the attachment is inadequate to redress the harm inflicted, harm that could have been avoided had an early hearing been held. An individual with an immediate need or opportunity to sell a property can neither do so, nor otherwise satisfy that need or recreate the opportunity. The same applies to a parent in need of a home equity loan for a child’s education, an entrepreneur seeking to start a business on the strength of an otherwise strong credit rating, or simply a homeowner who might face the disruption of having a mortgage placed in technical default. Doehr, 501 U.S. at —-, 111 S.Ct. at 2118 (plurality).

Film and Countless Alien Eggs Essay

I was in the middle school. I still remembered the feeling when I first watched this film. It was so scary that I couldn’t even breathe, and I once dreaded that these aliens would come to our planet and destroy our humanity. There is no doubt that this film is a masterpiece in the Sci-Fi/horror film history. The director Ridley Scott made an amazing film. The story mainly tells about a commercial towing spaceship, which carries seven crew members, and receives a beacon form a planet, so they decide to check it out. Three of crew member Dallas, Kane and Lambert discover a derelict spaceship which contains countless alien eggs; one of these attacks Kane and makes him unconscious. After Kane is brought to the ship, the strange thing happens. An alien bursts from Kane’s’ chest and kills all the crew members except Ridley. By her intelligence and braveness, she finally kills the alien and escape from the spaceship. Films about UFO and spaceships are extremely popular in the film industry especially in America, but in other countries it’s not popular at all. I think it is because schools in United States focus more on educating students’ imagination and creativity. People love to see films about future world and extraterrestrial life. As we know, our universe is extremely large; a lot of people believe that aliens do exist somewhere. Some rumor says they visited us and government knew it, but for some reason they didn’t want people to know. The more government wants to conceal the existence of alien, the more people want to know the truth. That’s why Sci-Fi movies can succeed in the box office so well. The Alien is one of the most successful Sci-Fi movies in the history. Some people think it also can be categorized as a horror movie too. There are so many scary moments in this film; some are really gross and disgusting. The effect of chest bursting of Kane is still amazing; even it was a movie that filmed 30 years ago. Director created a very scary creature, the alien. They have no gender, or you can say they are hermaphrodite. They have no womb and reproduce really fast, and their blood is made by strong acid, which can penetrate several floors of the giant spaceship. It makes them hard to kill, and the scariest thing is they use human body to reproduce. Once the baby alien ready to go from its host, they will burst out from their father/mother’s chest and instantly kill him/her. The alien grabs all the audience’s attention. Its giant body and gross drooling mouth creates the scary atmosphere, which make audience dread and anxiety. The success of Alien was quite closely linked to the background of America at that time. The Alien was born in the era of the Cold War. People were living under the tremendous pressure from the other countries. The feeling of the panic to the uncertainty just like an alien was hiding in the darkness, which was going to kill someone. By watching this film, audiences can release the pressure and forget the pain of real life. The Alien is an amazing film, which blends elements of Sci-Fi and horror to create a very horror and fantastic film. I would love to watch this movie again and recommend to all the people who like Sci-Fi and horror movies.

The role of ApoE and its isoforms in Alzheimer’s disease The WritePass Journal

The role of ApoE and its isoforms in Alzheimer’s disease The role of ApoE and its isoforms in Alzheimer’s disease IntroductionThe ApoE gene (Physiological Functions)The ApoE isomersApoE AÃŽ ² Aggregation (Fibrillogenesis)AÃŽ ² Clearance by ApoE ApoE and Neuronal InflammationConclusionBibliographyRelated Introduction Research into the genetic causes of Alzheimer’s disease have progressed considerably and currently at least three different genes are known to be linked with AD pathogenesis. Of these the apolipoprotein gene E (APOE), an amino acid glycoprotein, is one of the main focus of research over the last decade or so and significant associations between one particular isoform of the gene and the onset of AD have been reported. This isomer, referred to as the ApoE 4 allele, has been implicated in AD pathogenesis while other forms of the gene the ApoE 2 and the ApoE 3 have been reported to have a protective effect against the onset of AD. Though research has confirmed this variable effect of the different forms of the ApoE gene, there is still a lack of concrete evidence as to the exact pathway and the mechanism by which ApoE 4 contributes to neurodegeneration in AD patients.   A brief review of related research would provide us more insight into the various pathological actions of Apo E 4 and how these multiple factors could lead to a gradual cognitive decline which is symptomatic in Alzheimer’s patients. The ApoE gene (Physiological Functions) ApoE is an amino acid glycoprotein that is found mainly in the liver and the brain. In the brain, ApoE is predominantly secreted by the astrocytes. Two other forms of apolipoproteins namely ApoA-1 and ApoJ are also found in the brain. In vitro studies of these two genes have so far suggested that both of them exhibit a neuroprotective effect. Both these proteins bind to AÃŽ ² and therefore are thought to reduce AÃŽ ² aggregation in the brain which is a known marker of AD.   However, in vivo studies have not replicated such results and so the protective roles of ApoA-1 and ApoJ are not yet clear.   The ApoE supports cholesterol equilibrium by serving as a ligand during endocytosis of lipoprotein particles by LDL receptors. Research is divided in the opinion that the cholesterol released from ApoE mediated endocytosis process is actually used for improving the synaptic connections or the synaptic plasticity. Mice based in vivo studies have not attested to this synaptogenesis. (Kim et.al, 2009) The ApoE isomers Three single nucleotide polymorphisms of the ApoE gene are commonly identified in humans. These are the apoE2 (cys112, cys158), apoE3 (cys112, arg158), and apoE4 (arg112, arg158) respectively. (Kim et.al, 2009) The structural and functional aspects of the three isomers of ApoE are totally altered though they differ by only one or two amino acid positions.   Studies have reported strong immune-reactivity of the human apoE4 gene on amyloid plagues and the apoE4 isomer has been associated with having a strongest risk factor for AD. Some studies such as (Bertram et al., 2007) and (Bertram et al., 2009) have attested to this role of the apoE4 isomer in AD.   Bertram et al., 2009 for instance reported that people with a single copy of the apoE4 gene had a three fold increase in risk for AD, while the   risk was 12 fold among those with a dual copy of the ApoE4 gene.   The results from studies also suggest the possible role of some environmental factors as research based on some eth nic groups have revealed that the ApoE 4 gene does not have a significant effect on AD. ApoE AÃŽ ² Aggregation (Fibrillogenesis) Several research studies have focused upon the potential role of ApoE 4 in causing AÃŽ ² aggregation and neuronal degeneration. This direct interaction between the ApoE 4 with beta amyloid is attributed in the pathogenesis of the disease. Therefore it was hypothesized that increased levels of ApoE 4 in the brain corresponded to increased formation and thickness of amyloid plaques. The findings from one comprehensive study by Tiraboschi et.al (2004) validated this hypothesis. The researchers in this study confirmed increased plaque density corresponding to increased levels of ApoE 4. This positive association was again confirmed by a more recent study by Reiman et.al (2009). The researchers of this study used an amyloid detecting agent such as Pittsburgh compound B (PIB) along with positron emission tomography to detect the levels of fibrillar AÃŽ ² in the subjects. The researchers then correlated this information among individuals with varied genetic risks. The results from the study clearly revealed that ApoE 4 homozygotes had the highest risk (91%) for developing AD while ApoE 4 heterozygotes had a moderate risk of 47% and finally ApoE 4 non carriers had only 20% risk of having AD. Furthermore, the mean age of onset of AD was also vastly different with ApoE 4 homozygotes at 64, heterozygotes at 76 and 84 years of age among non carriers.   This longitudinal study clearly provides positive evidence connecting the ApoE 4 gene with a high risk for AD.   Thus there is enough evidence that ApoE 4 gene may aid in ï ¬ brillogenesis and consequent cognitive decli ne. (Reiman et.al 2009). AÃŽ ² Clearance by ApoE Some studies have shown that ApoE by binding with soluble AÃŽ ² promotes the cellular uptake and ingestion of the ApoE –AÃŽ ² complex   Ã‚  by endocytosis.   However, isomer specific results for this ApoE facilitated cellular uptake of AÃŽ ² are still awaited.   Research has also focused on the possible clearance of   AÃŽ ² from the brain via the blood brain barrier. However, there is growing evidence that ApoE 4 might actually hinder or reduce this clearance of AÃŽ ².   Deane et.al (2008), a study based on mice reported that the clearance rate of ApoE 4 –AÃŽ ² complex is much lower than that for the ApoE2 and ApoE 3 complexes. Other recent studies such as Bell et.al (2007) and Ito et.al (2007) that focused on studying the AÃŽ ² clearance in humans found that the clearance rate along the Blood Brain Barrier (BBB) was significantly lower for the ApoE 4 –AÃŽ ² complex compared to that of simple AÃŽ ² peptides.   These studies offer enough evidence that ApoE 4 might actually increase the fibrillogenesis by directly affecting the AÃŽ ² metabolism in the brain. By reducing the clearance rate and promoting aggregation ApoE 4 gene definitely poses an increased risk factor for AD. ApoE and Neuronal Inflammation Several studies have reported that ApoE has marked anti inflammatory properties which explain the surge in their production in the aftermath of an injury. These studies hypothesize that ApoE is needed for maintaining the cholesterol homeostasis, and in particular for increasing the availability of cholesterol for neuronal repair and improving the synaptic plasticity subsequent to brain injury. (Slezak Pfriege, 2003 ). However studies have also reported differences in neurite growth and synaptic plasticity post neuronal insult in animal studies based on the genotype.   One transgenic mice study found that neuronal growth and synaptogenesis were markedly lower among ApoE 4 transgenic mice compared to ApoE3 transgenic mice. (White et.al, 2001) An extensive review of the neuroprotective effects of the various ApoE isomers by (Cambon et al, 2000) clearly showed differential effects between the isomers. Most of the studies reported that ApoE3 promoted synaptic plasticity and neurite gro wth. However similar positive results were not witnessed in the case of ApoE 4 alleles with some studies even reporting the negative effects of ApoE 4 on synaptic plasticity and neuronal growth.   Colton et.al (2004) found that the anti-inflammatory effects vary drastically between the ApoE isomers.   The researchers studied this variability in anti-inflammatory response triggered by the ApoE 3 and ApoE4 isomers by using in vivo experiment conducted on ApoE knockin mice. By studying Lipopolysaccharide (LPS) mediated inflammatory responses the researchers observed the differences between the isomers. The inflammatory response was much greater in the ApoE 4 knockin mice when compared to the ApoE3 Knockin mice. These studies suggest that the anti inflammatory response maybe less active in ApoE 4 and this might lead to neuronal damage as witnessed in AD patients.  Ã‚   (Kim et.al, 2009) Conclusion The review of studies has revealed that the ApoE isomers have differential effects on the AÃŽ ² metabolism in the brain. While the ApoE 2 and ApoE 3 isomers have been reported for their protective effects the ApoE 4 allele clearly seems to contribute to the AD pathogenesis. Results from recent fibrillar PET imaging studies suggest a clear positive correlation between the ApoE 4 allele and the density of amyloid plaque formation. It is clear that by slowing down clearance of AÃŽ ² as well as contributing to its aggregation in the brain, the ApoE 4 allele increases the susceptibility of a person for AD. It is also possible that the ApoE 4 also lowers the protective function by increasing the neuronal inflammatory response and by hindering neurite growth. More studies are necessary to understand the complex relationship between ApoE and AÃŽ ² and the levels of different isomers of ApoE and their corresponding impact on Neuroinflammation and neurotoxicity, etc. Bibliography Jungsu Kim, Jacob M. Basak, David M. Holtzman, (Aug 13th 2009), The Role of Apolipoprotein E in Alzheimer’s disease, Neuron 63. Bertram, L., McQueen, M.B., Mullin, K., Blacker, D., and Tanzi, R.E. (2007) Systematic meta-analyses of Alzheimer disease genetic association studies: the AlzGene database. Nat. Genet. 39, 17–23. Bertram, L., McQueen, M.B., Mullin, K., Blacker, D., and Tanzi, R.E. (2009). The AlzGene Database Alzheimer Research Forum available at, alzgene.org. Eric M. Reiman, Kewei Chen,Xiaofen Liu et.al (Apr 2009), Fibrillar amyloid-ÃŽ ² burden in cognitively normal people at 3 levels of genetic risk for Alzheimers disease, Proc Natl Acad Sci U S A.  ;  106(16): 6820–6825. Bell, R.D., Sagare, A.P., Friedman, A.E., Bedi et.al (2007). Transport pathways for clearance of human Alzheimer’s amyloid beta-peptide and apolipoproteins E and J in the mouse central nervous system. J. Cereb. Blood Flow Metab. 27, 909–918. Ito, S., Ohtsuki, S., Kamiie, J., Nezu, Y., and Terasaki, T. (2007). Cerebral clearance of human amyloid-beta peptide (1-40) across the blood-brain barrier is reduced by self-aggregation and formation of low-density lipoprotein receptor-related protein-1 ligand complexes. J. Neurochem. 103, 2482–2490 Part 2 Fibrillar amyloid-ÃŽ ² burden in cognitively normal people at 3 levels of genetic risk for Alzheimers disease   (Reiman et.al 2009) This research study by Reiman et.al (2009) hypothesized that fibrillar amyloid accumulation is an early development in the onset of Alzheimer’s disease.   The researchers further hypothesized that the fibrillar amyloid accumulation precedes any recognizable symptoms of cognitive decline. Amyloid plaques are a distinct feature of AD as observed from post mortem studies. Given the hypothesis that fibrillar AÃŽ ² accumulation is observed even in healthy, non symptomatic adults, the researchers intended to study the effect of fibrillar AÃŽ ² burden as a predictor of future onset of AD on adults with normal cognitive function using Ante mortem  brain imaging studies. For this study, the researchers used Pittsburgh Compound B (PiB), a radio ligand that binds only with the fibrillar AÃŽ ² species. Earlier studies have also used this PIB for imaging studies of live human brain to observe the formation of fibrillar AÃŽ ² in healthy adults. This study by the authors is aimed to extend the previous studies by providing a genetic risk analysis and to understand the predisposition to AD based on an individuals APOE genotype. The APOE genotypes were identified by using blood sample analysis. The researchers used fluorodeoxyglucose PET, volumetric MRI and neuropsychological tests. Fibrillar imaging was done using 3 dimensional HR+ scanner.   The subjects of this study were all cognitively normal and late middle aged people representing a mixture of APOE genotypes. This was a longitudinal study and the subjects were assessed every 2 years. The researchers observed that cerebral glucose metabolism levels of those subjects carrying dual copy of the ApoE 4 (homozygotes) was significantly lower than that of the heterozygotes and the non carriers. With the PiB Pet images the researchers compared and correlated the fibrillar burden with the genetic risk to understand the predisposition for AD between the various isomers. The average Pittsburgh(PiB) distribution volume rations(DVR), which is a measure of the fibrillar AÃŽ ² accumulation, was on increase in all the three different groups in the 2 years period. One of the homozygote subjects developed mild amnesia and her DVR was close to that of an AD patient. Overall of all the 28 subjects (8 homozygotes, 8 heterozygotes and 12 non carriers), the ROI measurements pertaining to the different brain regions such as temporal, parietal, posterior cingulate-precuneus, basal ganglia, etc, was the highest among the homozygotes. The researchers used statistical analysis and found that the homozygotes had considerably higher ROI values when compared to the non carriers (P   .05) while the difference between the heterozygotes and the non carriers was not significant (.05   P   .11). When correlated the APOE4 and Fibrillar AÃŽ ² burden was found to be significant among both homozygotes and heterozygotes compared with the non carriers. The study authors successfully found that even in cognitively normal individuals there is a positive correlation between ApoE 4 and fibrillar AÃŽ ². The results from the study suggest that the ApoE 4 is clearly associated with increased AÃŽ ² aggregation and decreased AÃŽ ² clearance. The following PET map clearly indicates the various regions of the brain that are affected by AÃŽ ² accumulation. Group A represents the homozygotes while group B and C represent the heterozygotes and non carriers respectively. Longitudinal studies are very effective in following the growth of fibrillar AÃŽ ² accumulation as they provide a clear pattern of disease progression even in the asymptomatic stage. People who are in late middle age who are at risk for AD would greatly benefit from a prophylactic intervention based on the brain mapping study and their ApoE genotype. This study clearly contributes to our understanding that the ApoE 4 is directly involved in the AÃŽ ² interaction and the formation of Amyloid Plaques. By considering live brain images for the study the authors were able to clearly confirm the association between the ApoE 4 and AÃŽ ² fibrillar density and predict the increased susceptibility of people with that genotype. This study has large implications for the treatment of AD. By proving that AÃŽ ² fibrillar formation precedes a perceivable cognitive decline, this study recommends early interventions particularly for people with ApoE 4 genotype, as the current AÃŽ ² modifying treatments would be more effective before extensive AÃŽ ² accumulation has occurred. The researchers advocate the use of brain imaging studies combined with genotype based risk assessment as a potentially powerful tool in preventive therapy for people who are at a genetically high risk for AD. One of the drawbacks of the study is the very small study sample. A large cohort based longitudinal study would have provided more conclusive confirmation of the study results. Bibliography Eric M. Reiman, Kewei Chen,Xiaofen Liu et.al (Apr 2009), Fibrillar amyloid-ÃŽ ² burden in cognitively normal people at 3 levels of genetic risk for Alzheimers disease, Proc Natl Acad Sci U S A.  ;  106(16): 6820–6825.

Free Essays on Public Education Vs. Private Education

Public Education v/s Private Education A person’s education is one of the most important factors in determining whether or not they will become a productive member of society. That is why when considering an education the quality of the education is almost as important as the education itself. So when private schools came into the picture the debate then began between public and private schools. Facing the technological revolution that we are going through without a good quality education a person will be left behind. Even though public and private schools are separate institutions they have to follow certain guidelines so there are a lot of similarities between the two. Such as, both school systems have the intentions of giving their students the best education within their means. Both have educated professionals that have decided to devote the rest of their careers to furthering the education of our youth. They each have set up rules hoping to keep it a positive learning env ironment. They both use standardized testing as a tool to evaluate the progress of their students. They can also access the weaknesses from these tests to improve the curriculum that they have composed. They also have clubs like volunteer groups that help out people in their surrounding community. There are also student governments where students elect students to improve upon the learning environment in which they are. Schools also have extra curricular activities like sports where students compete against other schools where they learn school spirit and how to work as a team. With all of these activities students can hopefully find something that they enjoy spending their free time. This also hopefully keeps children out of trouble. Private schools have a lot to offer. The most important thing they bring to the table is the high standards that they set. With the majority of the students wanting to achieve at such high levels this creates a very positive learnin... Free Essays on Public Education Vs. Private Education Free Essays on Public Education Vs. Private Education Public Education v/s Private Education A person’s education is one of the most important factors in determining whether or not they will become a productive member of society. That is why when considering an education the quality of the education is almost as important as the education itself. So when private schools came into the picture the debate then began between public and private schools. Facing the technological revolution that we are going through without a good quality education a person will be left behind. Even though public and private schools are separate institutions they have to follow certain guidelines so there are a lot of similarities between the two. Such as, both school systems have the intentions of giving their students the best education within their means. Both have educated professionals that have decided to devote the rest of their careers to furthering the education of our youth. They each have set up rules hoping to keep it a positive learning env ironment. They both use standardized testing as a tool to evaluate the progress of their students. They can also access the weaknesses from these tests to improve the curriculum that they have composed. They also have clubs like volunteer groups that help out people in their surrounding community. There are also student governments where students elect students to improve upon the learning environment in which they are. Schools also have extra curricular activities like sports where students compete against other schools where they learn school spirit and how to work as a team. With all of these activities students can hopefully find something that they enjoy spending their free time. This also hopefully keeps children out of trouble. Private schools have a lot to offer. The most important thing they bring to the table is the high standards that they set. With the majority of the students wanting to achieve at such high levels this creates a very positive learnin...

6 Boundaries You Need to Protect at Work

6 Boundaries You Need to Protect at Work The pressure seems to be up these days, in almost every field. The workdays are longer, the weekends start to disappear. You might tell yourself you leave it at your desk, but then find yourself checking work emails on your phone at midnight before you fall asleep. Or worse, plugging in during vacation, when you’re supposed to be a million miles away from your job. But this kind of prolonged stress can actually be bad for both your health and your job performance. It is important to establish boundaries between the personal and the professional, to keep both parts of our lives healthy and productive.There are some things you simply do not owe to your employer. Here are 6 of them:1. Your HealthYour health is yours and only yours and only you can keep it up. It’s on you if the stress buildup happens so gradually that you don’t notice the effects of lack of sleep and hunching in your chair and not exercising or eating right. Before you turn into the office zombie, m ake sure to set up a routine that works for you. And make sure it includes work/life balance, mental space, rest time, and exercise. Once you make your plan, don’t let that one extra email from your boss derail it. Stick to your guns.2. Your FamilyWe all want to work harder to be able to support our families- make that little extra bit of money and push that little bit  further. But it can be easy to lose sight of how much you have to sacrifice to bring that extra home. Make sure you’re not sacrificing time. At the end of your life, you won’t regret not having that $8k raise. But you might regret not being home for dinner with your kids.3. Your SanityNo one can monitor this but you. And no boss should chip into your supply. Figure out what keeps you sane and balanced (hint: it’s probably your life outside of work) and make sure to claim both time and space for that. Know when it’s more productive to say no to a request, knowing you’ll work much better and harder if you’re relaxed and recharged and can tackle things afresh.4. Your IdentityWho you are is immensely important. What you do is only part of it- a big part, admittedly, but not everything. Keep in mind the things that are most important to you. Stay true to your values and maintain your integrity. This helps you keep your eye on the bigger picture in times of major stress at work.5. Your Professional ContactsYou owe your employer a lot. But your contacts from over the course of your career are yours. You can- and often should- share them with your company, but they are yours first and foremost and you must work to maintain them.6. Your IntegrityKeep your actions and beliefs in alignment, or you will feel horribly stressed and uncomfortable with the results. This is part of keeping the other five in check. Stay true to who you are and what you need and what you believe in. Act according to the best of yourself. If a boss asks you to compromise this, it might be time to find another boss.Remember: never underestimate the power of setting good boundaries.

Nuclear Power Research Paper Example | Topics and Well Written Essays - 500 words - 1

Nuclear Power - Research Paper Example Energy experts build huge dams in order to seize the water, which generates hydropower energy. Consequently, these constructions disrupt flow of rivers, which further result to plausible natural calamities for example, overflows in rivers. In addition, the construction of dams facilitates the impediment of natural flow of sediments in the river. Variably, the impediment results to rivers losing their banks. Moreover, individuals lose their existence because of the evictions, which follow the construction of the dams (Murray 2009). Development of nuclear power facilitates the following consequences: first, from the Fukushima Nuclear Disaster an individual depicts that the power supply in a nuclear plant suffers susceptibility of disability. For example, the machinery at Fukushima experienced a major nuclear accident because of the consequent chilling of the elements of retort. In addition, there are usually, constant releases of radioactive materials, which poison such paramount phenomenon as rivers (Bodansky 2004). Variably, contaminated waters from the plants leak out and cause melanoma and other precarious ailments to individuals. However, the Fukushima Nuclear Plant presents such advantages as generation of a significant high amount of energy from that single plant. Consequently, the plant does not release green house gases, which result to negative aftermaths of worldwide warming. Clearly, unconventional sources of power produce harmful green houses gases hence causing mountains to lose their snowing abilities (Bodansky 2004). Second, the Chernobyl Nuclear Meltdown released twenty five percent of radioactive reactor materials. Additionally, the historical accident registers deaths of individuals and continuous re-settlement of people who lived around that area. Further, there were various psychological impacts on the people who experienced the Chernobyl accident (Bodansky 2004). Although

Banking and international banking system Essay Example | Topics and Well Written Essays - 2000 words

Banking and international banking system - Essay Example Major financial institutions collapsed or near collapsed and credit markets were frozen. Bear Stearns and Sachsen LB (German bank), banks fell in 2007. It was followed by IndyMac Bank in receivership and demise of Lehman Brother in the quarter of 2008 (Drea 2009). After September 2008, panic in the financial global sector escalated and spread to other sectors of the economies. Investors were shocked by losses that they incurred on assets they thought were safe. There was strong evidence that contagion was linked with global financial crisis. This happened through liquidity and risk-premium channels in the financial markets. There was clear evidence informed by research that contagion during subprime crisis was clearly shown by significance of t-statistic for lagged ABX index returns in 2006 (Longstaff, 2010). Cross-market linkages were stronger and significant during subprime crisis indicating that that 2007 subprime crisis resulted in large shifts in trading activity, liquidity and funding in the financial markets across the world. A number of reasons have been advanced concerning the recent global financial crisis. ... The foreign money was savings piling up and owners wanted to invest their monies away from home where they were assured of some returns. The net inflow of foreign savings into the United States in 2006 was about 6 percent of the United States’ output. Instead of investing foreign moneys appropriately, financial institutions in the United States that received the surplus funds from Asia converted the monies to loans that were aggressively given to borrowers, especially homeowners. Mortgage market was attractive to investors because over 80 percent of mortgage market in the United States was securitized and they that their monies would be invest well (Financial Crisis Inquiry Commission, 2010). Securitization created the much needed diversification to investors and liquidity for business entities and individuals. Securitization refers to pooling mortgages together as securities. Once pooled as securities, they are sold to investors. However, investors and players in the industry lacked the business acumen to realize that securitization lacked clarity and transparency. Financial institutions also underestimated the risk associated with securitization and sold mortgage backed securities to investors across the world. The investors, which included banks, money markets, pension hedge and mutual funds, purchased the mortgage backed securities thinking they were safe. However, securitization was not able to provide protection against systematic risks. Even, credit rating agencies failed to take into account systematic risks and awarded the mortgage backed securities with AAA rating because it was considered low risk securities. Therefore, credit rating agencies could not price systematic risks into subprime mortgage pools. In

Criminology Theory Essay Example | Topics and Well Written Essays - 1000 words - 1

Criminology Theory - Essay Example In this movie, the views and characters of Derek are shaped by his neo-nazism beliefs. Derek is recruited into this group by Cameron Alexander, the neo-nazi leader. Alexander appoints him as the leader of the Caucasian kids. His role was to lead them against the Hispanic and the Black kids. Their attitude against them was shaped by the belief that these kids they lost their freedom and destiny to these people of different race. The Hispanics and the blacks were foreigners whose main aim was to exploit the resources of United States of America. On this basis therefore, Derek joined the group of the skinheads because of inequality in resource allocations, and he adapted their violent methods of agitating for their rights. The movie shows this by when he led a group of skinheads to destroy a Korean canteen. However, while in prison, Derek changes his ways of view. This is because he came to learn that there was a need of collaborating with each other, irrespective of race to survive. This is because of the inter-racial commerce that was pre-dominant in the prisons. The violent behaviors that Derek had were as a result of his failure of self-control, because he had already subdued the thieves, and he was not facing any threat. For instance, ordering the thief to open his mouth and busting his head with a bullet was a very cruel method of killing an individual. He could also control the manner in which he made his speech that had an effect of causing a violent mass action by the skin heads. The tone of his voice was harsh, and his words were full of incite. On this note, had Derek used some soft words, the riot that came as a result of the speech could not occur. It was possible for Derek to refuse the offer by Alexander, because he was not forced into joining the group. On this basis therefore, the behavior of Derek came as a result of his inability to control

Discussion Of The Article About The Australopithecus Essay

Discussion Of The Article About The Australopithecus - Essay Example The essay "Discussion Of The Article About The Australopithecus" discusses the meaning of the term Australopithecus mean and the different historian aspects regarding the australopithecines. Australopithecus africanus seems to be the closest ancestor or relative to the Homo genus. It had unique features that were less primitive than A. Afarensis. It had a flat face, evidence of stronger chewing force, a bigger jaw, and great sexual dimorphism, which meant the males and females looked very different and had different sizes and weights. Their skeletal architecture suggests shifts related to environmental and dietary forces. The main differences between the anatomy of Australopithecines and Paranthropus were their jaws and chewing apparatus. Their diet meant they needed stronger jaws and bigger chewing and grinding teeth, which affected their cranial size and shape. They had cheekbones that jutted forward. They also had a relatively smaller body. Paranthropus robustus, found at the South African cave site of Kromdraai, in Swartkrans, and also the limestone cave of Drimolen, in South Africa, is about 1.8 - 1.5 mya; Paranthropus Boisei, excavated at the Olduvai Gorge, Tanzania and thought to be 2. - 1.3 mya; and Paranthropus aethiopicus, discovered in the Omo River valley in southern Ethiopia, and on the western shore of Lake Turkana in northern Kenya, estimated to be about 2.5 mya. There is also a jaw fragment from Baá ¸ ¥r el-GhazÄ l in Chad, and a Homo erectus specimen called ‘Turkana Boy’.

Challenges of restaurant operations in new Jersey Essay

Challenges of restaurant operations in new Jersey - Essay Example New Jersey is one of major tourist destinations in wildwood, Ocean City, Point Pleasant beach, fishing villages, beautiful barrier islands and scenic views. With all these we expect local and foreign tourists in these areas. To accommodate foreign tourists, there are several restaurants which serve as dining and accommodation avenues (Wilkerson, 2008). We shall look into details management of these restaurants and the overall effects of internal administration challenges, external factors and come up with possible mitigation strategies to these challenges. Management of restaurants is associated with several challenges due to the need of the industry to incorporate varied client needs and preference, develop and maintain the company image and to stand relevant businesswise. Managers of these restaurants and relevant stakeholders have to make decisions from administrative point of view and try to incorporate other factors such as state laws and provided statutes, demographic and geogr aphic factors to enhance operations of the restaurant. In the administration perspective managers are faced by several challenges which include; training of the staff, they should be trained to understand the menu items, how to respond to customers and overall organization flow within the restaurant. For instance, training of the front office employees may be different from those of the kitchen section otherwise known as back house operations. Training of front office employees who may include cashiers, waiters/waitresses and customer care requires diligence as they are the face of the restaurant. They need to understand different languages, be resilient to different attitudes of customers and the general customer-friendly attitude. Training of the back office staff has challenges in that they need to meet varied tastes and preferences of different customers because the kitchen section is the heart of the restaurant. To address this, employees need to be trained and attached to thei r areas of specialization. This is to bring the competitive aspect of the business in terms of quality services to the customer which is a necessity for image and brand development. Another challenge in restaurant management is cultural integration. Most restaurants employees are either immigrants from other states or from different regions with different cultures and incorporating these cultures in a single work force is a challenge. To address this challenge training and integration of cultural heterogeneity will be of paramount benefit to the restaurant and customers. Unpredictability is another challenge in a service industry where you cannot tell who is visiting today, what they will order and what is in stock. There could be a crisis if the operations for instance were expecting a thousand visitors, then the number increases and there are no radical measures to meet the increased demand. To address this, I would stand-by employees in case of an influx, gather reliable informat ion on tourist trends so as to enable procurement procedures and be flexible on duty allocation to the employees. Social concerns are another challenge facing restaurant industry in terms of amenities such as hygiene, security and incorporation of varied tastes and preferences of different visitors. These challenges can be addressed by understanding particular needs and want of the visiting clients and coming up with measures to