The Spiritual Autobiography Essay Example for Free

The Spiritual Autobiography Essay One of the fascinating characteristics of Japanese religion is the syncretism of its traditional religions, foremost of which are Zen Buddhism and Shinto. In Journey In Search of the Way: The Spiritual Autobiography of Satomi Myodo, Satomi gives a mesmerizing look into the spirituality of Japan, through the eyes of what seems at first an unlikely witness. Satomi’s experiences are untypical for a Japanese woman in the Meiji era, considering that she was the only daughter of her parents. Petty (2004) argues that by being an only child, Satomi received her parents’ whole investment of expectations and dreams, a burden of responsibility in any society. Thus she was subjected to experiences that a village girl at that time would normally not have, such as her education in Tokyo, her subsequent unwed pregnancy or her arrangement as a Kageki actress. Her unique encounters as both a Shinto miko and a Zen nun are an insight to the mixture of the two religions in modern Japan. When Satomi first engaged in ascetic practices, she was doing it to prepare herself to become a miko. Initially, she was not satisfied with her experience, rather describing herself afterwards as no better off than she was before. This purification process is not unique to the Shinto religion, but her struggles can be classified as more of a shamanistic nature reflecting her encounters with the kami. Satomi continued to engage in an ascetic lifestyle afterwards, in her discovery of Zen. According to Nixon (2000) â€Å"At this point Satomi’s asceticism is less severe, and she consciously relates it to her practice of meditation, but it serves a similar function – i. e. , one of deliberately frustrating a lower level structure of dependency, in order that the dynamisms of a higher level of personality might emerge, as indeed they do with her first kensho experience. † (par. 14). Although she found true enlightenment and spiritual invigoration in the practice of Zen, her initial experience in purifying the spirit with Shinto has given her prior introduction to the life she will lead as a Zen nun. Additionally, Satomi’s failures and accomplishments in her role as a woman in the Meiji-era society gave her the character and persistence needed in her pursuit of satori. By practicing zazen, Satomi found great peace and joy, something she was searching for since the very beginning. It can be argued, however, that her Shinto preparation was a stepping stone towards finding enlightenment. Her first kensho experience, at fifty-nine years old came late in life, and her dedication towards this experience made her a model of achievement in any religious path. Zen and Shinto were at the time of Satomi separated, with Shinto following the Kannagara no michi tradition that was used in pre-war Japan to instill a nationalistic spirit on the Japanese. From the start however, the influence of Buddhism on Shinto is apparent and the best example would be the description of Kannagara no michi as teaching a primal state of natural and spontaneous harmony with the kami, to which one might return by abandoning human desire and artificiality. This incorporation of beliefs is characteristic of the faith of modern Japanese people today, which take Shinto and Buddhist teachings as part of the culture and spirituality of Japan. Satomi’s account is clear and vivid, giving justice to the setting and context of her life’s story. The Journey In Search of the Way: The Spiritual Autobiography of Satomi Myodo is a very good reading on the religions of Japan, and especially in relation to the role given to women. R E F E R E N C E Nixon, Laurence. (2000). A Dabrowskian Analysis of a Japanese Buddhist Nun [Electronic Version]. The Dabrowski Newsletter, 6(2). Petty, Genevieve. (2004). A Wild Woman in Buddhism: A Critique of the Life of Satomi Myodo. Retrieved April 7, 2007, from http://poeme. memory-motel. net/academic/satomi. pdf

Mariette in Ecstasy Essay -- Literary Review

In the book Mariette in Ecstasy, Rob Hansen paints a story of the extraordinary happening at a priory in upstate New York. His depiction of life in the priory is centered around the newly inducted Mariette Baptiste, the young and beautiful daughter of a local physician, and the disputed events that threaten to tear the priory apart from within. Rob Hansen does an incredible job of placing the reader in the priory for themselves and allowing them to see just what kind of life the sisters live. On Mariette’s first day, the women rise at five o’clock to a ritualized call and response, where Sister Hermance shouts, â€Å"In Jesus Christ, my sisters, let us rise!† and the sisters respond with, â€Å"His holy name be praised!† (Page 5). The women follow a rigorous and regular schedule for the rest of the day. Embedded in their lifestyle are a lot of rituals and intricate tasks, which have been almost completely legitimized by their repetition. The women of the priory also live a highly ascetic life, believing that the hard work performed and simple living conditions in themselves alone can give rise to an experience that is greater than anything achievable through other worldly goals. Mariette herself writes prayerfully, â€Å"Were it necessary to give up all the worldly pleasures of my life to gain one instant of happiness for you, I would do it without hesitation.† (Page 135). The way the sisters go about living their spiritual life has a touch of Peter Berger’s idea of masochism to it as well. In Mariette’s talks with Pà ¨re Marriott, she says, â€Å"as I began to meditate on the crucifixion and Christ’s own trials in this world, I became rapt in thought and I found myself again before Jesus, who was suffering such terrible pain†¦An unquench... ... common problem of theodicy. If God is good, why would he not help his own followers and prevent them from being led astray? The act of calling in a surgeon implies that religion is not â€Å"good† or â€Å"powerful† enough which calls into question the order of things within the priory and even the plausibility structure that has been securely established for so long. Ron Hansen for the most part avoids directly addressing these religious issues; instead Mariette in Ecstasy aligns more with what Mikhail Bakhtin argues a novel is, a presentation of many perspectives. In the end these two perspectives both have their own idea of what the objective truth of the presented world is, and while Ron Hansen avoids directly presenting one side as the one that’s right, his novel brings up the existence of more than one side, which alone is more than many similar religious works do.

Issues, concerns, and challenges in environmental adjucation in the philippine court system Essay

Introduction The court system is an integral part of environmental enforcement in the Philippines and has made many important contributions to the field. However, environmental cases do not always progress smoothly through the judicial system. This paper is intended to identify important legal issues in the judicial system that affect or limit environmental adjudication. 2 The issues are divided between access to and competency of justice, and legal procedures. While many of these issues could be analyzed further, this paper will highlight the ones to which attention should be paid in any more comprehensive study of Philippine environmental case law. 3 This paper will also use examples and case studies from the United States to illustrate important legal points, since the U. S. and Philippines have similar legal systems. II. Issues A. Legal Procedure and Rules of the Court Because of their unique and complex nature, environmental cases are sometimes hindered by legal mechanisms and rules of procedure designed for non-environmental cases. These include rules on standing and class action suits that often do not take into account the fact that environmental damage impacts all citizens. Furthermore, the nature and science of environmental violations often means that statutes of limitations, evidentiary rules, and burdens of proof are not suitable. Some of these issues can be handled internally by the judicial system by instructing lower courts to apply rules liberally. The impact of all of these issues, and how many actually present problems for plaintiffs, is crucial. 1. Standing of Plaintiffs and Citizens Suits In environmental cases, a plaintiff may not necessarily be legally injured in the traditional sense by an act of environ-mental destruction to impair his livelihood. For example, plaintiffs cannot recover damages for fish killed by pollution because they lack standing, despite the obvious economic loss they suffered. 4 While the destruction of natural aesthetic beauty is a moral outrage that indirectly harms all citizens, under traditional legal standing person no would have standing to sue. 5 Furthermore, environmental laws are designed to prevent catastrophic harm that is often not imminent or contained to one geographic area, as opposed to the narrow, immediate harms that provide the basis of most standing requirements. 6 Strict rulings on standing could stifle environmental enforcement, especially since the Philippines lacks sufficient enforcement capacity and personnel. The Philippine Supreme Court has held that standing requires: Such personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court depends for illumination of difficult constitutional questions. 7 The plaintiff himself must have some cognizable and redressable injury. Litigating for a general public interest, or â€Å"mere invocation†¦ of [plaintiff’s] duty to preserve the rule of law†¦ is not sufficient to clothe it with standing†¦. †8 However, the standing requirement is considered a technicality that courts may waive if the case concerns a â€Å"paramount public interest. †9 In its dictum in Oposa v. Factorum, the Court said that children might even have intergenerational standing to sue to prevent the destruction of forests for future generations. 10 There are questions as to the strength of these to reduce the standing threshold for environmental plaintiffs. While courts may waive technical standing provisions when a case deals with a paramount public interest, it is not required to do so. 11 Furthermore, judges may reasonably differ on what constitutes a â€Å"paramount public interest† since there is no overriding theme o define it. For example, in Kilosbayan, the Court found that determining the legality of an online lottery system fell within this definition, whereas in Integrated Bar, it held that determining whether deploying marines for crime deterrence violates the Constitution does not. 12 The Court did reduce some of this ambiguity in Oposa by declaring that the right to a balanced and healthful ecology â€Å"concerns nothing less than self-preservation and self-perpetuation,† presumably a â€Å"paramount public interest. †13 However, because the Court’s discussion on standing in Oposa was dictum, neither this claim nor the right to intergenerational standing is binding law upon the lower courts. 14 Without further guidance from the Court, it is likely that many lower court judges would be reluctant to act boldly by declaring that a particular issue is a â€Å"paramount public interest† and would deny standing. Congress tried to reduce the standing threshold with citizen suit provisions in environmental statutes, but these have been of limited use thus far. First, only the Philippine Clean Air and Ecological Solid Waste Management Acts contain citizen suit provisions;15 notably, the Philippine Clean Water Act, enacted after these two laws, does not. 16 Second, citizens still bear the risk of paying a winning defendant’s attorney’s fees, which could be costly enough to discourage even valid suits. Most importantly, these suits are still subject to the â€Å"actual controversy† requirement of the Constitution. 17 What this means in the context of citizen suits has not yet been heavily litigated in the Philippines. However, lower court judges often require plaintiffs to show actual injury in the narrow or traditional legal sense. 18 Likewise, when prosecutors deputize citizens to enforce a suit, judges sometimes insist that such deputization is only valid for a single case or even invalid under the Rules of the Court. 19 As a result, citizens suit provisions have been largely unused. 20 Standing under environmental laws is hotly contested in the U. S. 21 The U. S. has put citizens’ suit provisions into almost all of its environmental laws. 22 Plaintiffs are required to show 1) an injury in fact, 2) causation between the injury and the defendant’s actions, and 3) redressability in court. 23 NGOs can sue upon a showing that any of their members would have had standing to sue. 24 The focus is not on the injury to the environment, but rather the injury to the plaintiff or NGO representing him. However, the injury can be economic or non-pecuniary, including aesthetic or recreational value. 25 The Court also held that civil penalties payable to the U. S. Treasury serve as redress as they deter polluters. 26 Causation is often the more difficult element to prove, which will be discussed below in  § 4. In New Zealand, the Environment Court has taken a more radical approach. It has eliminated formal standing provisions, requiring only that a plaintiff have a greater interest than the public generally in a controversy or that he represents a relevant public interest. 27 This makes citizen enforcement very easy. However, one might also be concerned about whether this would overburden the court; granting standing is a fine balance between permitting valid environmental claims and risking frivolous litigation. 2. Class Actions and Large Number of Plaintiffs As the notorious mudslide at Ormoc in 1991 and Marcopper mine tailings in Marinduque show, injuries from environmental damage can be grave, costly, and affect a huge number of persons. 28 Even in less publicized events, the number of injured persons may often make individual litigation burdensome and complex. Furthermore, some members of an injured class may be too poor to prosecute their claims individually. Class action suits can facilitate litigation of such situations by providing for: [T]he protection of the defendant from inconsistent obligations, the protection of the interests of absentees, the provision of a convenient and economical means for disposing of similar lawsuits, and the facilitation of the spreading of litigation costs among numerous litigants with similar claims. 29 Other studies have shown that class action suits can provide important social benefits and encourage citizen enforcement to supplement agency regulation. 30 Class actions may the discourage attorney disloyalty that encourages lawyers to plea bargain for less than the actual injury. As happened in the Chinese poachers case in Palawan, lawyers or prosecutors may not seek full compensation for the damage caused because they have an incentive to expend less time and money on a small case. 31 However, because class actions provide aggregate incentives for lawyers, and fees and settlements undergo higher judicial scrutiny, such â€Å"disloyal† settlements are less likely to occur. 32 While the Philippine Rules of the Court provide for class action suits,33 judges will sometimes be reluctant to certify classes and instead treat the injuries of plaintiffs as separate, despite any common questions of law or fact. In Newsweek, Inc. v. IAC, the Supreme Court ruled that a defamatory remark directed at 8,500 sugar planters do not necessarily apply to every individual in a group, and therefore are not actionable as a class action. 34 Likewise, a judge might refuse to certify a class of pollution victims because they suffer different types of physical injuries, even if the source was the same pollution. In a more litigated legal system, there would be more case law to guide judges on the appropriateness of class actions. However, in the Philippines, this does not yet exist. Add to this the high cost for lawyers, and class actions become even less feasible for most Philippine plaintiffs. 35 In the U. S. , it is much easier to litigate environmental class action suits. The Supreme Court has clearly instructed courts to construe its class action rules liberally and encourage class action suits. 36 This limits judicial discretion in refusing to certify classes to only extreme situations. Furthermore, the rules allow plaintiffs to join by default rather than affirmatively. 37 For environmental cases, the courts will look at the potential number of plaintiffs or the size of the estimated areas that a pollutant has infected to see if plaintiffs have met the numerosity requirement, but they are not required to meet a certain minimum number. 38 For the Philippines, which, unlike the U. S. , has too few environmental class action suits, adopting some of these mechanisms may create a more efficient adjudication process for plaintiffs, defendants, and the courts. 3. Statute of Limitations and Delayed Injuries Unlike a traditional tort or crime, many environmental injuries are not discrete events but only manifest themselves after many years. Pollutants may build up in soils, waters, or human bodies for years without reaching a dangerous level. Cleanup of such sites can take even longer. For example, when the U. S. military left Subic Bay in 1992, it left behind hazardous waste sites with contaminated water that continue to poison the land over a decade later. 39 However, for environmental torts, the statute of limitations is four years, a relatively brief time. This could preclude the litigation of injuries from pollutants with an onset delayed for many years. Thus far statutes of limitation issues have not been a significant factor in environmental litigation. The Philippine Supreme Court addresses similar problems in other fields of law with the discovery rule, allowing the statute of limitations to run when the plaintiff actually or should reasonably have discovered the injury. 40 However, as the courts handle more brown environment cases, it will have to address the tensions between punishing past violators and protecting defendants from time-barred claims. 41 U. S. courts have adopted the due diligence discovery rule, particularly for Clean Water Act and wetlands violations. Because immediate detection of pollution or illegal fill into a wetlands is almost impossible, applying a statute of limitations strictly would defeat the remedial purpose of the act. 42 Courts try to effectuate the Congressional purpose of the statute with the due diligence discovery rule and giving the government a chance to file action against the polluter once the violation is reported to the EPA. 43 Some courts44 realize that a statute of limitation may be inappropriate for cases when pollution continues to cause problems over time. These courts argue that a: Defendant’s unpermitted discharge of dredged or fill materials into wetlands on the site is a continuing violation for as long as the fill remains. Accordingly, the five-year statute of limitations †¦ has not yet begun to run. 45 The statute of limitation will not run for as long as the pollution remains. Many courts will also treat common law tort nuisances as continuing violations. 46 This approach has the added benefit of allowing the government to fine violators for each day the pollution remains, capturing the more of the costs of environmental destruction. 47 Much of U. S. case law regarding the effect of statutes of limitations on environmental issues comes from ambiguities in the statute of limitation for complex processes, particularly the Comprehensive Environmental Response, Compensation and Liability Act (â€Å"CERCLA†), or Superfund law. 48 Because Congress anticipated the complexity and long-term nature of site cleanups, it structured the statute of limitations in a flexible manner, allowing the court hear an initial cost recovery action prior to issuing a declaratory judgment to avoid letting the statute run. It also allows the plaintiff to file subsequent cost-recovery actions to recapture further response costs incurred at the site. 49 However, the law’s different statutes of limitation for remedial and removal actions phases of the cleanup has led to confusion over how the phases are defined. Courts often defer to EPA determinations in characterizing the type of action due to its technical expertise, rather than making that judgment itself. 50 4. Meeting the Burden of Proof In environmental cases, there may be no line of direct evidence from the perpetrator to the harm. In pollution cases it is often impossible to prove that the plaintiff’s harm was caused by his exposure to the toxic material. 51 For example, if several factories dump pollution into Manila Bay, it is impossible to determine which caused a particular environmental harm. Furthermore, the courts cannot expect absolute scientific certainty on the effects of a health risk such as electro-magnetic fields from power cables. 52 Given these problems, the traditional burden of proof standards, preponderance for civil cases and beyond a reasonable doubt for criminal,53 may prove to be prohibitively high. Philippine courts employ liability-shifting mechanisms to manage this difficulty in environmental cases. For example, pursuant to the Fisheries Code, courts use reverse burden of proof to place the burden of exculpation on defendants found with high-explosive or cyanide fishing gear. 54 Furthermore, the courts have begun to experiment with the precautionary principle, placing the constitutional rights to health and safety above development. 55 The courts also employs res ipsa loquitor in tort suits,56 although this has not been a prominent feature of environmental litigation. Plaintiffs may also hold multiple defendants jointly and severally liable for an act of environmental destruction that cannot be traced to a single defendant company, such as the pollution in Manila Bay. 57 Until recently, Philippine lawmakers did not see a need to introduce a strict liability58 regime into environmental laws. 59 Strict liability was employed in other fields, but not environ-mental laws. More recent anti-pollution laws such as the Clean Air and Solid Waste Management Acts establish that a violation of the standard is actionable through citizen suits. 60 In U. S. , because of its common law tradition, courts are more willing to employ strict liability. Generally, when a defendant, â€Å"though without fault, has engaged in [a] perilous activity †¦, there is no justification for relieving it of liability. †61 Such â€Å"perilous activities† include operating explosives, nuclear energy, hydropower, fire, high-energy explosives, poisons, and other extremely hazardous materials. 62 For citizens suits under environmental statutes, plaintiffs need only show that the law was violated, not prove fault or any actual or threatened harm, without regard to mens rea. 63 When it is impossible to determine the proportion of fault of a large number of defendants, U. S. courts may approximate fault through other indicators, including market share and production output. For example, in Hymowitz v. Eli Lilly ; Co. , the New York Court of Appeals calculated the size of each defendant drug company’s market share for DES to determine their fault in the injuries caused by the drug. 64 This also allows courts to address injuries sustained in the past by approximating past fault through data available in the present. The Environment Court in New Zealand has adopted an even more radical approach and done away with formal burdens of proof. It focuses instead on obtaining the best possible evidence for a case. This makes it easier for plaintiffs appealing to the court to dislodge an unfavorable opinion from a lower court. 65 While the Philippine Supreme Court may not wish to go this far, the court could more strict liability for hazardous materials and market share liability tools. 5. Damages and Remedies Even if a plaintiff wins damages from a defendant, if the defendant keeps polluting or cutting trees, the damage will continue. 66 In the Philippines, this is particularly problematic as the fines and penalties imposed under law are often not enough to change a company’s behavior. In order to encourage development, Congress prohibited temporary restraining orders against government projects. 67 Since government infrastructure projects can cause massive damage to ecosystems, this prohibition is significant. Some courts try to avoid this loophole by claiming that the prohibition cannot violate a person’s constitutional right to health or safety. 68 The extent of this loophole is unclear. Finally, even if a plaintiff or prosecution wins its case, most of the time the true costs of the defendant’s actions will not be reflected in the award. Damages in civil cases and punishments in criminal cases generally capture the costs of any suffering caused to humans, not animals or plants. While some settlements may include forcing a defendant to install pollution-control equipment or contribute money to conservation programs, this still likely does not recoup the full extent of damage to the environment. It is difficult to regenerate natural forest, coral reefs, or populations of endangered animals. The judicial system does not have much power to remedy this problem. The decision on the purpose of environmental laws and how much plaintiffs recover is for the Congress. However, it is important for judges to understand that environmental cases deal with only a fraction of the true costs of environmental damage. This may convince some judges to be more sympathetic toward environmental cases. While punishments for defendants may seem exorbitant, understanding the unaccounted costs of environmental damage puts these into perspective. B. Access to and Competency of Justice Aside from the legal issues described above, in any country, there are a host of practical and logistical issues that impede the judicial system’s ability to handle environmental cases. This includes the lack of financial resources of plaintiffs, particularly in poorer parts of the Philippines. Plaintiffs and their lawyers must also feel safe from physical and financial harassment while litigating their case. On the other hand, both courts and lawyers are often unfamiliar with environmental laws and science, limiting their ability to adjudicate in the field. Finally, court dockets are often congested, and environmental cases are not given priority. The judicial system’s role in addressing these issues ranges from fairly involved to almost no role. Yet, in attempting to understand environmental adjudication in the Philippines, it is crucial to recognize the role these practical realities play. 1. Financial Costs of Adjudication In any legal system, filing and litigating a case takes an enormous amount of time and money. Philippine courts impose a filing and transcript fee, although these are waived for citizens suits. Reflecting on his experiences, famous environmental attorney Antonio Oposa suggested that these costs were the greatest inhibitions for most plaintiffs. 69 Furthermore, for injunctive remedies, plaintiffs must post a bond to cover the defendant’s potential damages, which may be too large for a poor plaintiff with livestock and property as his only assets. 70 Most Philippine lawyers do not use a contingency fee system, so plaintiffs must be able to pay for legal services up front and over the lengthy litigation process. 71 On top of this, there is the risk of financially crushing harassment suits from defendants, or Strategic Lawsuit Against Public Participation (SLAPP). Even the logistics of feeding and housing witnesses, and their lost time from work, poses significant problems for predominantly poorer plaintiffs. In the U. S. , NGOs often receive enough donations to allow them to engage in litigation and have staff lawyers. More importantly, plaintiffs’ attorneys often work on a contingency basis, allowing poorer plaintiffs to avoid large financial risk. Furthermore, NGOs and environmental groups seeking injunctive remedies are often required only to pay a nominal bond or may be exempted completely. 72 While some might worry this makes litigation in the U. S. too easy, it drastically improves poor people’s access to justice. Pursuant to the Constitution’s emphasis on the poor, the Supreme Court of the Philippines has taken some efforts to alleviate this problem. Poorer plaintiffs are exempted from paying docket, transcript, and other fees and are granted free legal counsel. Furthermore, the Court provides an annual grant to the Integrated Bar of the Philippines’ Free Legal Aid Program. 73 However, not all environmental plaintiffs qualify as poor, particularly NGOs, even though they often have limited financial resources. Furthermore, even though the amount of the bond is under the discretion of the judge, judges are reluctant to do this because they worry about being accused of abusing their discretion. 74 2. Harassment of Plaintiffs and Lawyers Because of the high stakes involved in environmental cases, defendants may go to extraordinary means to intimidate and harass plaintiffs and their lawyers. It is not uncommon for defendants to lodge harassment or SLAPP suits against environmental plaintiffs or DENR prosecutors to attempt to force them to drop their charges. 75 Enforcers who confiscate the equipment of criminals are often sued for robbery. 76 Some defendants take even more extreme means such as physical violence or even murder. 77 Such dangers were recently illustrated by the murder of environmental advocate Elpidio de la Victoria and death threats against attorney Oposa. 78 This makes lawyers unwilling to take on difficult environmental cases. To stifle SLAPP suits, the courts should promptly apply the anti-SLAPP provisions in the Philippine Clean Air and Ecological Solid Waste Management Acts when applicable. 79 This means dismissing any harassment suits as quickly as possible. However, plaintiffs relying on other laws have less protection. 80 Congress must expand the use of anti-SLAPP provisions to other environmental laws. Furthermore, law enforcement must vigorously prosecute any defendants who resort to violence. In short, to facilitate environmental cases, the court must protect the ones bringing the cases. 3. Technical Knowledge Among Judges and Attorneys Judges must decide questions of science as well as law in order to dispose of most environmental cases. This is particularly true for brown issues, which involve uncertain science regarding the exact effects of a pollutant. In the U. S. , scientific understanding of pollutants led to new classes of trespass and tort suits that held emitters liable for their actions. 81 However, both sides in a case will try to use any scientific uncertainty to their advantage, or even create scientific uncertainty even when it does not exist in order to confuse the court. Judges must understand what scientific evidence should be admitted and what is not valid. 82 Judges and lawyers need to understand the science well enough to determine which arguments are unfounded and which are plausible. Because general the courts have general jurisdiction and are not specialized in environmental issues, this problem will have to be addressed by providing judges and lawyers with supplemental training in environmental sciences and law. PHILJA and other organizations are already successfully doing this. 83 Eventually, however, this problem may be resolved through a change in the adjudication system. If the Philippines moves toward environmental courts or administrative adjudication84 (as is being considered), judges would be trained specifically to handle environmental cases. 4. Obtaining and Preserving Evidence For green issues, preserving evidence may be difficult. After an illegal logger or fisher is captured, DENR can confiscate the logs and fish. These goods rot or deteriorate over time. Proper procedure requires taking pictures of the logs and fish for admission into court. Specially trained fish examiners prepare reports on the cause of death of fish. When done correctly, this preserves the evidence for use at court. However, some areas may not have fish examiners on hand or the prosecution may not properly prepare the pictures for admissible evidence. It is not uncommon for custodians of the confiscated items to lose track of them over time. Because cases take so long in the court system, this can be a real problem. 85 It is also difficult for enforcement agents to find and confiscate the equipment and vehicles used in environmental crimes, as the boats and trucks perpetrators use are highly mobile. Despite the inconvenience it may cause defendants, such equipment must be held as evidence and to prevent further environmental damage. The accused, or unindicted conspirators, will often petition for the release of their equipment. 86 Unfortunately, sympathetic lower court judges may sometimes grant these requests, despite the contravening case law. 87 Moreover, prosecutors must have the vehicles stored in a safe area despite the lack of storage space. Finally, it is important for enforcers to determine the location of violators, particularly close to the boundaries of natural parks. Community enforcers may not be trained in determining the exact location of where they apprehended the violators. Wealthier units can use GPS, but often the location of apprehension is disputed. 88 Any doubt in this area can destroy the prosecution’s case. 5. Docket Congestion In many countries, including the Philippines, courts are overburdened with cases. Yet, the Philippines’ forests and animals are already disappearing quickly. Irreversible damage to ecosystems can occur much more quickly than the many years it may take the court system to resolve a case. As Prof. La Vina noted, the environment cannot wait for the court system. 89 According to Justice Nazario, the Philippines needs over 300 trial court judges to fill the vacancies and resolve pending cases. 90 Low pay discourages the few who are qualified. Many of these vacancies are in remote parts of the country, such as Nueva Ecija, Occidental Mindoro, and Surigao Norte, where much of the fishing and forestry violations occur. Furthermore, the Supreme Court is burdened by the large amount of cases granted review each year, including the automatic review for death penalty cases. 91 Given this burdensome congestion, environmental cases are not given any special treatment on their own merits. Criminal environmental cases may be somewhat more expedited because they involve criminal punishments, but most judges and lawyers show no urgency with regard to environmental cases. 92 The Supreme Court attempted to alleviate this problem with Administrative Order No. 150B-93, setting up special courts to handle illegal logging, but these remain underutilized. 93 Until cases can move through the court system more quickly, the enforcement of environmental law will be delayed. III. Conclusion This paper has highlighted important legal and practical issues preventing efficient adjudication of environmental cases in the Philippines. However, due to logistical and budgetary constraints, this paper focused mostly on case law from the Supreme Court and the personal experiences of lawyers. In order to fully understand environmental adjudication throughout the court system, further research should ideally analyze environmental cases from all Municipal and Regional Trial Courts, Courts of Appeal, and the Supreme Court. It is important to see how cases area actually treated, particularly with respect to the issues examined in this paper. Furthermore, there may be important regional variations, particularly between areas with more natural resources and more urban areas. Even before such a study is undertaken, the courts can apply several lessons from this paper in the near future. First, while the courts have already taken commendable steps to waive filing fees and other costs for paupers, as mentioned above the definition of pauper may be under inclusive by not including NGOs. The courts should consider other definitions to reflect the realities of environmental NGOs. 94 Second, the Supreme Court should instruct the courts to dismiss SLAPP suits expeditiously. While the natural resource laws may not have anti-SLAPP provisions, Congress clearly did not intend to encourage such suits and there is nothing legally preventing the courts from dismissing them faster. Finally, the courts can address standing for citizens and class action suits. In particular, it should set out a clear position on standing in environmental cases. Other challenges will require long-term planning for the courts. Reducing the docket congestion is critical to expedite justice, although doing this will likely take years and require more judges. Likewise, the ongoing effort to train judges and lawyers in environmental law and science must continue, particularly as new judges and lawyers enter the judicial system. The courts should also familiarize themselves with the legal mechanisms available to them, particularly in shifting the burden of proof. However, this will be most useful in pollution cases as they become more common in the future. Ultimately, the challenges described above will require multifaceted solutions from various stakeholders in the Philippine legal system. For example, Congress must work to improve standing and citizens suit provisions in other environmental laws. To reduce the financial risk of brining a suit, law firms could move toward a contingency fee system. Furthermore, it is the responsibility of DENR and environmental agencies to ensure that evidence is properly recorded and preserved. Finally, as the Philippine grows and wealth spreads, more plaintiffs will be able to undergo the financial costs of adjudication. Eventually, the best solution to these challenges may come not from within the courts but from a new adjudication system. The U. S. has worked successfully with administrative adjudication for environmental issues in the EPA and Department of Interior. Other countries have set up independent environment courts. Based on the results of further studies and the needs of the country, the Philippines may move to adopt one of these models. This would allow expert adjudicators to handle cases under rules that make sense for environmental issues. Finally, it is important for judges at all levels of the judicial system to understand the severity of environmental degradation in the Philippines. The only redress environmental plaintiffs or prosecutors may have is in their court. Thus, they should not be reluctant to grant standing or award large damages, when appropriate, because doing so will ensure that both humans and the environment have their proper day in court.

Preventing Youth Suicide Essay - 2131 Words

Youth suicide is a public health concern. Suicide is the fifth leading cause of death among children ages 15-24. Recently, more young people died from suicide than from cancer, heart disease, diabetes, and other medical conditions combined (Miller, Mazza, Eckert, 2009). The Centers for Disease Control and Prevention have stated that since the 1950s, the rate of suicide in youth has increased by more than 300 percent (Joe Bryant, 2007). The number of youth suicides that are reported is actually lower than the actual number of youth suicides. Suggested by the literature, this is due to concern for the family, the social implications, religious views and other factors (Page, 1996). Is suicide preventable? Can we reduce the number of†¦show more content†¦For example, nine out of ten individuals who commit suicide give clues to others before a suicide attempt (King, 1999). Warning signs include: rage, anger, seeking revenge; acting reckless or engaging in risky activities, seem ingly without thinking; a feeling of being trapped, as if there is no way out; increasing alcohol or drug use; withdrawing from friends, family, or society; experiencing anxiety and/or agitation; being unable to sleep or sleeping excessively; dramatic mood changes; and perceiving no reason for living or no sense of purpose in life (Miller Eckert, 2009). It is suggested that youth who speak of suicide should be taken seriously because it is not just talk. Those individuals are the most likely to attempt suicide (King, 1999). Students who are suicidal will try to talk to anyone that will listen about their suicidal thoughts, so people should be available to students and accepting to be that person that the student feels that they can go to (Helsel, 2001). To understand these warning signs, one has to know what causes these behaviors to come about. One of these aspects has to do with risks that come from school difficulties. Risks from school difficulties Research states that youth who have difficulties in school are at an increased risk of committing suicide (Walsh Eggert, 2007). Risk factors can help explain or predict youth suicidal behaviorsShow MoreRelatedThe Impact Of Youth Suicide On Australia And Usa And How It Can Be Prevented1517 Words   |  7 Pagesimpacts of youth suicide and how it can be prevented. 1.2 Parameter To investigate the impacts of youth suicide in Australia and USA and how it can be prevented 1.3 Thesis Society should take notice of signs of youth suicide such as depression and reduce the stigma related to suicide and help them cope and prevent any further unnecessary deaths. 1.4 Definition Suicide is the action killing oneself with intent (WHO, n.d) â€Æ' 2. BACKGROUND TO THE ISSUE: 2.1 Introduction Youth suicide is one ofRead MoreHow Suicide Can Be Prevented? Essay1043 Words   |  5 Pageshow Suicide can be prevented in teens? I found that, in 2010, there were nearly 2,000 suicides in youth. (U.S Department of Health Human Services). This article is relevant to my research question because it shows that suicide is an important issue for young people that are facing in life. For this reason, there had been many cases of suicide and attempts mostly in youth. Suicide is a serious problem it should be looked at and not take it as a game. In fact, for the past few years suicide has beenRead MoreA Look Inside Teen Suicide Essay1221 Words   |  5 Pagescorner, and the only solution you see, the only way out, is suicide. In the present, it seems that the number of youths that are depressed, hurting themselves and thinking suicidal thoughts are increasing. Youth suicide has slowly been crawling its way up the cause of death list and is now the third leading cause of death in youth from ages ten to twenty-four year olds (Washington State Department of Health â€Å"Teen Suicide†). Youth suicide is a growing social problem that needs to be brought to attentionRead MoreHealth Outcomes1611 Words   |  7 Pageshealth population problems. Measuring the health of children is important because the youth are citizens that are unable to act as self-advocates at the population level and their health determines the health of the population in the future. Child health measurement indicators are central in identifying priorities, progress, problems, newly emergent issues, and changes over time (Rigby ump; Kohler, 2002). Youth violence, childhood obesity, childhood asthma, and pre-term births are a few chil dhoodRead MoreTeenage Suicide On The Rise Essay1521 Words   |  7 PagesTeenage Suicide on the Rise: In 2011, James Rodemeyer, a 14 year old junior high school student from Buffalo revealed his bisexuality via the World Wide Web. The weeks following Rodemeyer experienced taunting, name calling, assault and isolation from his peers. Even his close friends refused to sit with him at lunch. Later that year, James Rodemeyer committed suicide.This case is just one of many where an adolescent feels that their is no other solution than to end their life. It is estimated thatRead MoreTeen Suicide And Teenage Suicide1357 Words   |  6 Pagestake a more proactive step to prevent teen suicide by giving their students and staff more of an education. For example the Ontario Shores Mental Health Science wants schools to be more aware also; â€Å"Last week the Durham school boards announced a new curriculum to teach teachers about mental illness in youth, funded by the Ontario Shores Centre for Mental Health Sciences in Whitby.† ( Scallan and Chantaie). A town in Ontario brought this iss ue of teen suicide up to the school board. The school boardRead Moreâ€Å"Dying Before Their Time: The Startling Trends in Adolescent Suicide†1217 Words   |  5 PagesAmerican Academy of Child and Adolescent Psychiatry (AACAP), suicide is the third leading cause of death for adolescents aged 15-24 years old. This calculates to 33,000 adolescents killing themselves each year (CDC, 2010). The National Conference of State Legislatures (NCSL), reported that suicide amongst all individuals nation wide has declined over all, but despite the decline, adolescents between the ages of 15 and 19 have shown suicide rates that has increased by 6 percent (NCSL, 2005). The mostRead MoreSuicide Rates Among Youths Aged890 Words   |  4 PagesSuicide rates among youths aged 15-24 tripled over the past half-century suggesting a public health crisis in this community.4,16 Many general studies of the youth community are in existence, but to create an action plan, the individual risk factors a nd characteristics need to be better understood. One risk factor of particular interest is sexual orientation. Studies suggest an increased risk of suicidality in sexual minority youth (SMY) and the purpose of this paper is to better understand thisRead MorePermanent Solution For Temporary Problems1418 Words   |  6 PagesApril 27, 2016 Permanent Solution for Temporary Problems With suicide being the 3rd leading cause of death among young teens, it is vital that we educate ourselves and others on the warning signs and risk facts because the more information obtained contributes to preventing suicidal thoughts and attempts. Close your eyes and imagine twelve children ages nine to twelve, now imagine each one committing suicide either by cutting, strangling, suffocating, firearm, jumping, or overdosingRead MoreYouth Suicide A Growing Problem Essay1373 Words   |  6 Pages Youth Suicide a Growing Problem Megan Roth September 7th 2015 Mineral Area College Submitted in partial fulfillment of the Associates of Nursing degree to Mr. Richard Wadlow Abstract The purpose of this paper is to research youth suicide. In this paper I plan to cover the basics of youth suicide, who is affected, warning signs to look for, how to help those with dealing with this issue and several research studies on youth suicide. Introduction I will be covering

All About Hogs and Pigs

Hogs and pigs (Suidae), also known as suids, are a group of mammals that includes domestic pigs, babirusas, pigs, warthogs, forest hogs, red river pigs, and bushpigs. There are sixteen species of hogs and pigs alive today. Hogs and pigs are stout, medium-sized mammals that have a stocky torso, an elongated  head,  short legs, and small pointed ears. Their eyes are often small and positioned high on the skull. Hogs and pigs have a distinct snout, the tip of which consists of a round cartilaginous disc (called nasal disc) with their nostrils on the end. The nasal disc is attached to muscles that enable pig to move their nose with precision as they sniff their way along the ground foraging for food. Hogs and pigs have an acute sense of smell and a well-developed sense of hearing. Hogs and pigs have four toes on each foot and are therefore classified among the even-toed hoofed mammals. Hogs and pigs walk on their middle two toes and their outside two toes are placed higher on their leg and do not come into contact with the ground when they walk. Hogs and pigs range in size from the pygmy hog (Porcula salvania)—a critically endangered pig that when full grown measures less than 12 inches tall and weighs less than 25 pounds—to the giant forest hog (Hylochoerus meinertzhageni)—a bulky suid that grows to more than 3.5 feet tall at the shoulder and weighs in at an impressive 350 pounds or more.  Adult female hogs and pigs and juveniles form groups known as sounders. Adult males either remain solitary or form small bachelor groups. Pigs are not usually territorial and exhibit aggression between individuals during the mating season. Hogs and pigs once inhabited a native range that extended across Europe, Asia, and Africa. Humans introduced domesticated pigs, derived from the species Sus scrofa, to areas throughout the world including North America, New Zealand, and New Guinea. Fossil hogs and pigs occur in the Oligocene in Europe and Asia and in the Miocene of Africa. Diet The diet of hogs and pigs varies among the different species. Many  hogs and pigs  are omnivores but some are herbivores. In general, the diet of  hogs and pigs  includes: Plant material such as grass, leaves, and rootsInvertebrates such as insects and wormsSmall vertebrates such as frogs and mice Classification Hogs and pigs are classified within the following taxonomic hierarchy: Animals Chordates Vertebrates Tetrapods Amniotes Mammals Even-toed hoofed mammals Hogs and pigs Hogs and pigs are divided into the following taxonomic groups: Babirusa (Babyrousa) - There are four species of babirusa alive today. Members of this group include the  golden babirusa,  Sulawesi babirusa, Togian babirusa, and  Bola Batu  babirusa. Babirusa  are noted for the long upper canine teeth that, in males, curve back over their face.Warthogs (Phacochoerus) - There are two species of warthogs alive today, the desert warthog and the common warthog. Warthogs inhabit the dry grasslands and scrublands of sub-Saharan Africa.Forest hogs (Hylochoerus) - There is one species of forest hog alive today, the giant forest hog,  Hylochoerus meinertzhageni. The giant forest hog is considered to be the largest wild member of the Suidae. The giant forest hog inhabits woodland habitats in central Africa.Bushpigs and red river hogs (Potamochoerus) - Only two living species belong to this group, the bushpig (Potamochoerus larvatus) and the red river hog (Potamochoerus porcus). Both species inhabit sub-Saharan Africa.Domestic and wild pigs (Sus) - There are six species of pigs alive today. Members of this group include domestic pigs and wild boar (Sus scrofa), Visayan warty pigs (Sus cebifrons), and Philippine warty pigs (Sus philippensis). References Hickman C, Roberts L, Keen S.  Animal Diversity. 6th ed. New York: McGraw Hill; 2012. 479 p.Hickman C, Roberts L, Keen S, Larson A, lAnson H, Eisenhour D.  Integrated Principles of Zoology  14th ed. Boston MA: McGraw-Hill; 2006. 910 p.

Essay on The Benefits of Uniform Adoption in Public Schools

Ever wonder what it would look like to have all students wearing the same white polo shirt, black pants, and a district sweater walking in the hallway? Nowadays, public school and many districts are discussing the possibilities of enforcing the uniform policy. In most places, many private schools already require students to have their mandatory uniforms; however, there are only a few public schools adopting this mandatory school-uniform polices as one of their enrollment requirements. The reason why not all public schools participated was because people believe that they are violating the freedom of choice when enforcing this mandatory uniform policy; yet problems such as bullying and segregation, emerged in these schools. Some people†¦show more content†¦Apparently, they came to school unprepared. Referring to the article â€Å"What the United Kingdom Can Teach the United States about School Uniforms†, Angela Walmsley accentuates that â€Å" When issues surrounding the dress code are diminished, there is more time for student learning†(Walmsley 66). Young adolescents get distracted easily compared with the mature adults. Fancy goods always attract people by their fantastic look and bring them to the fashion side. Consequently, students would pay more of their attention to the latest fashion instead of their school work. Then the school work will not be done on time because majority of their time is spent on the fashion. Without paying attention and making great efforts, school work can only be abandoned eventually. However, like Walmsley emphasized, when public schools require their students to wear the mandatory uniform, students will not have any struggle about choosing what clothes to wear today and tomorrow. In other words, students will have more time spending on school work. Another point is that the purpose of students going to school is gaining knowledge and preparing for their future. Students learn how to dress formally as a st udent in school. The adoption of this district uniform could help them to prepare the way professionals dressed. The next advantage of public school uniforms can be identified as theShow MoreRelatedOver The Past Years, Most Public School Administrators1385 Words   |  6 PagesOver the past years, most public school administrators have been engaged in the heated debate over whether public school students should put on school uniforms or not. This important argument has drawn the attention of both liberal thinkers and conservatives. From one far end, a section of the society feels that public school students school have the freedom to put on their clothing of choice while the other section feels that there should be uniformity in the public-school attire. Based on such contradictingRead MoreSchool Uniforms Persuasive Essay1470 Words   |  6 PagesThe Benefits of Uniform Adoption in Public Schools Ever wonder what it would look like to have all students wearing the same white polo shirt, black pants, and a district sweater walking in the hallway? Nowadays, public school and many districts are discussing the possibilities of enforcing the uniform policy. In most places, many private schools already require students to have their mandatory uniforms; however, there are only a few public schools adopting this mandatory school-uniformRead MoreShould School Uniforms Be Banned?1667 Words   |  7 Pagestold me when I was little, â€Å"Schools should be schools, not fashion shows.† The debate as to whether there should be uniforms at school only began in the 20th century. In 1994, Long Beach California School District integrated school uniforms for all elementary and middle school students, in order to address safety issues challenging the district. According to the school district data, within one year of the implementation of uniforms, crime rates dropped by 91% , school suspensions dropped by 90%,Read MorePersuasive Essay On School Uniforms1671 Words   |  7 Pages Hari Mainali South University School Uniform â€Æ' Abstract Freedom of dress is violated by restricting on school uniform. A school and university have their own dress code which does not require a particular dress. Some researcher and scholar suggest misbehavior in the student are the result of banning uniform. But misbehavior is what they acquired in their life. Banning uniform, student can exercise their right to express themselves freely. Student will be able to focus on education and saveRead MoreSchool Uniform Policies Within School Systems Essay1474 Words   |  6 Pagesdebate over the implementation of school uniform policies in school systems has been seen widely across the United States The decision of uniforms being implanted in school systems is based off the state or the individual schools policy. The school either can make uniforms mandatory or voluntary. Schools have policies that convey the expectation of acceptable appearance, such as going to school in a properly dressed manner. In 1996 the percent of schools that had uni forms was 3%. As a result of this lowRead MoreDebate on School Uniforms1191 Words   |  5 PagesHowever, most public schools are turning to something more casual and more acceptable to parents and students: khakis or jeans and knit shirts of varying colors. The latter appear to be more affordable too because they can be used outside of school. Many school districts that have implemented school uniforms have provided some sort of financial assistance for families that can not afford the extra expense. 2. Potential Benefits of School Uniforms • Decreasing violence and theft because of clothingRead More Opposing School Uniforms Essay examples1684 Words   |  7 PagesSchool Uniforms In 1993, Will Rogers Middle School in California’s Long Beach County School District began discussing the idea of a school-wide uniform policy. That fall, Will Rogers became the first school in Long Beach County to have a mandatory uniform policy. Other schools in the district soon followed drawing national attention, including a personal visit from then President Clinton. Recent memories of school shootings around the nation caused President Clinton to urge other school districtsRead MoreSchool Uniforms1566 Words   |  7 Pagesfor School Uniforms A safe and structured learning environment is the first requirement of a good school. Children who feel safe and secure will better learn basic American values. In return they will learn the basis of good citizenship and become better students. In response to growing levels of violence in our schools, many parents, teachers, and school officials have been forced to look toward school uniforms as one potentially positive way to reduce discipline problems and increase school safetyRead MoreArgument Against School Uniforms Should Not Be Banned1556 Words   |  7 PagesArgument Against School Uniforms My disagreement against school dress code is that public schools should not make the student go to school uniforms. Students should be able to wear any appropriate clothing they want to wear. School uniforms are not the way to be unsuccessful in education. School uniforms are a waste of time to have in a public school system. Teachers should make the students go home and change into school appropriate clothes. Public schools should give students a chance on what theyRead MoreThe Convergence of Two Accounting Systems and the International Financial Reporting Standards1318 Words   |  5 Pagesreceivable, changes in estimates and extraordinary items, inventory accounts, schools, businesses, retraining of CPA and the list goes on. If IFRS takes place and is fully embedded as our primary standard of accounting, what would be the long-long term effect of convergence? Since, IFRS only applies mostly on publicly held companies. How it affects the accounting principles and standards for non-public held companies? How will public and private companies reconcile their books? Since, IFRS has no clear

JITTERS COFFE RESTAURANT Essay Example For Students

JITTERS COFFE RESTAURANT Essay Jitters gourmet coffee has been around since 1972. The founders of the caf originated from Nevada, where the first Jitters was born. People in Las Vegas have been enjoying Jitters coffee for years. The franchise in Tempe wasnt built until the 80s. But the history that is really interesting is the social history of the Jitters at Arizona State University located on University and College Street. Many people waltz in and out of Jitters everyday, you may even be one of these people who on route to class make a quick stop into the sandy brick building. But as you exit the building did you notice the small crack at the base of the wall. Where an upset employee threw a tray of mugs? Most likely not, This is one of the many stories that have been shared with me by employees of Jitters, regular customers of Jitters, and people who have never stepped foot into the caf at all. With a restaurant that has been around as long as Jitters has you are bound to have some good tales to tell. One begins with an innocent looking collegiate sophomore strolling into the caf. As he strutted into the caf with ill intentions he assessed the local talent residing within the edifice. He couldnt help but want to sit next to the only dark haired woman sipping on a java in the corner. The attack was on, recognizing the book she was reading he approached her with a nonchalant question. Are you studying for the math test this week? He knew she was, and her answer as expected was, yes. It was all down hill from here. Playing the innocent schoolboy, he skillfully manipulated past her hesitant demeanor, and convinced her into studying with him that night at the cafe. He met her at Jitters as planned and the night turned into a great study session. Which he planned, as he did not want to seem overly aggressive or desperate. As the night winded down so did her guard, he asked her if she would like something to drink. She was very receptive to his proposal. He chose a nice expresso with a shot of amarettto. He could tell that after studying with her for the whole night she was trusting to his open conversation with her. He asked her about her current dating status, which was single, the attack now sped towards a closing. Acting as if he was concerned with her safety, he asked her if she wanted him to walk her back to her dorm. At first she said, no, playing hard to get, but he rolled with it. And told her he had to walk that way anyway. At least his foot was still in the door. His last chance resided in the goodbye at the dorm room door. As they neared the dorm he constantly reminded her of how smart she was and how she didnt have to worry about this math test being as intelligent as she was. When they reached her dorm and she whispered in his ear Would you like to come up and watch a movie? Steve celebrated silently and replied if thats alright with you of course it was and so he did and to this day Steve and Jessica are still together, and frequent Jitters caf as often as possible. For this happy couple Jitters is a great place to mingle and meet people. But then there is the other side of the spectrum. Where Jitters serves as a job. One employee, Chrissy, has a completely different perspective. She sees another side of Jitters. .ude8bd284166f00a292627f97ba2483e5 , .ude8bd284166f00a292627f97ba2483e5 .postImageUrl , .ude8bd284166f00a292627f97ba2483e5 .centered-text-area { min-height: 80px; position: relative; } .ude8bd284166f00a292627f97ba2483e5 , .ude8bd284166f00a292627f97ba2483e5:hover , .ude8bd284166f00a292627f97ba2483e5:visited , .ude8bd284166f00a292627f97ba2483e5:active { border:0!important; } .ude8bd284166f00a292627f97ba2483e5 .clearfix:after { content: ""; display: table; clear: both; } .ude8bd284166f00a292627f97ba2483e5 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ude8bd284166f00a292627f97ba2483e5:active , .ude8bd284166f00a292627f97ba2483e5:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ude8bd284166f00a292627f97ba2483e5 .centered-text-area { width: 100%; position: relative ; } .ude8bd284166f00a292627f97ba2483e5 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ude8bd284166f00a292627f97ba2483e5 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ude8bd284166f00a292627f97ba2483e5 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ude8bd284166f00a292627f97ba2483e5:hover .ctaButton { background-color: #34495E!important; } .ude8bd284166f00a292627f97ba2483e5 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ude8bd284166f00a292627f97ba2483e5 .ude8bd284166f00a292627f97ba2483e5-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ude8bd284166f00a292627f97ba2483e5:after { content: ""; display: block; clear: both; } READ: Essay on Facebook And Its Effects On Facebook Essay She has been in the caf daily for the past 2 years now, and has seen a lot occur. Chrissys feet sway around the caf with the greatest of ease, which seems ironic when you follow her long skinny legs up to her head where her short spiky hair gives you an evil look. Nonetheless, she refills your glass of coffee with a smile and returns behind the counter to the lookout, as she likes to call it. Ive seen some weird things happen here man let me tell you exclaims Chrissy. One night we .